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Transitioning to Safer Chemicals:

A Toolkit for Employers and Workers

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Why Transition to Safer

Alternatives?

Basics of Informed Substitution

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Success Stories

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Michaels' Introductory Video

Explore the Steps

Welcome.

American workers use tens of

thousands of chemicals every

day. While many of these

chemicals are suspected of

being harmful, 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. Workplace

chemical exposures have been

linked to cancers, and other

lung, kidney, skin, heart,

stomach, brain, nerve, and

reproductive diseases.

Establishing a chemical

management system that goes

beyond simply complying with

OSHA standards and strives to

reduce or eliminate chemical

hazards at the source through

informed substitution best

protects workers.

Transitioning to safer

alternatives can be a complex undertaking, but a variety of existing resources make it easier. OSHA has developed this

step­by­step toolkit to provide employers and workers with information, methods, tools, and guidance on using

informed substitution in the workplace.

By using this toolkit, businesses can improve worker well­being through eliminating or reducing hazardous chemicals,

while creating other benefits, including:

Cost Savings — Reduce expenses and future risks.

Efficiency — Improve performance.

Industry Leadership — Invest in innovation to stay competitive.

Corporate Stewardship — Advance socially responsible practices.

This toolkit can be used by all types of businesses—it is for manufacturers using chemicals in their production processes

as well as for businesses that use products containing chemicals in their everyday operations. For example, serviceoriented workplaces (such as janitorial companies, auto body repair shops, and pathology labs) and construction work

sites often use products containing chemicals that could present hazards to workers.

Workers also can use this toolkit to better understand chemical use in their workplace, find opportunities for using safer

chemicals, and engage with their employers throughout the process of identifying, evaluating, and transitioning to safer

alternatives.

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Engage

Inventory &

Prioritize

Identify

Assess &

Compare

Select

Test

Evaluate

Steps for

Transitioning to

Safer Chemicals

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OSHA wants to help businesses thrive safely by asking them to look at their chemical use and adopt ways to reduce the

use of hazardous chemicals. Together, OSHA, employers, and workers can protect America's workforce and strengthen

America's businesses.

Note: This website is advisory in nature and informational in content. It is not a standard or regulation, and it neither

creates new legal obligations nor alters existing obligations created by OSHA standards or the Occupational Safety and

Health Act.

This number is derived using the methodology from "Green Chemistry in California: A Framework for Leadership in

Chemicals Policy and Innovation," (http://coeh.berkeley.edu/docs/news/06_wilson_policy.pdf [PDF*]) to estimate

illness and deaths attributable to workplace chemical exposures.

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Transitioning to Safer Chemicals:

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Why Transition to Safer

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Watch Assistant Secretary

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Explore the Steps

Why Transition to Safer Alternatives?

It is widely recognized that the

most effective method to eliminate

or reduce adverse health and

safety outcomes in the workplace

is to eliminate hazards at the

source, before applying other, less

effective forms of protection. This

industrial hygiene principle, known

as the hierarchy of controls, has

been well­studied, widely accepted

and prominently incorporated into

practice by businesses and

industrial hygiene professionals

throughout the world.

In chemical management, this

hierarchy guides employers and

workers to eliminate or reduce

hazardous chemicals at the source

by substituting them with safer alternatives. Unlike traditional engineering controls, administrative controls, work

practice controls, or personal protective equipment, these strategies can completely eliminate exposure to hazardous

chemicals, reduce the potential for chemical accidents, reduce disposal costs, and remove concerns regarding worker

compliance and equipment maintenance.

Eliminating or reducing chemical hazards at the source, when coupled with a thoughtful, systematic evaluation of

alternatives and the adoption of safer chemicals, materials, products and processes, can provide substantial benefits to

both workers and businesses.

Improve worker health and safety: In the United States, it is estimated that chemicals are the cause of more than

190,000 illnesses and 50,000 deaths suffered annually by workers. These numbers are likely an underestimate due to

long latency periods between chemical exposures and the onset of disease, unrecognized relationships between

illnesses and chemicals, and other factors. Replacing known hazardous chemicals with safer alternatives could help

reduce these numbers.

Reduce costs: Using hazardous chemicals in the workplace results in substantial direct, indirect, and liability costs to

businesses and society. Step 4 of the toolkit outlines these in detail. Transitioning to safer alternatives can reduce

these costs, as well as improve other important measures of success, such as performance efficiency, industry

leadership and corporate stewardship. A 2008 study by the American Industrial Hygiene Association demonstrated that

making process improvements designed to reduce or eliminate workers’ exposures to hazardous chemicals resulted in

greater savings and other benefits than implementing controls further down the hierarchy (i.e., engineering controls,

administrative and work practice controls, and PPE).

Reduce potential for regrettable substitutions: Hazardous chemicals have the potential to be replaced with

substitute chemicals or redesigned products or processes that may pose new and potentially greater hazards to

workers. Implementing a process of informed substitution – which examines the hazard, performance, and cost of all

options – can protect workers and identify replacements that are unlikely to cause more problems or be a target of

future regulatory efforts.

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Achieve compliance with laws and regulations: Although federal, state, and local legislation in the U.S. has been

in place for many years to regulate chemicals (e.g., OSHA’s Occupational Safety and Health Act of 1970, EPA’s Toxic

Substances Control Act of 1976), in recent years new international, federal, and state regulations are now requiring

manufacturers, importers, and distributors to disclose more information about chemicals throughout the supply chain

(e.g., REACH ), avoid certain chemicals (e.g., Restriction of Hazardous Substances Directive (RoHS) , Maine Kids

Safer Products Law), and implement safer chemicals where feasible (e.g., EU Chemical Agents Directive , EU

Carcinogens and Mutagens Directive ). Additional laws and regulations restricting hazardous chemical use or

emissions are also on the horizon. The cost of not complying with existing laws or preparing for future efforts can be

substantial. For example, as a result of a European Union law restricting certain chemicals in electronics, 29% of 200

U.S. firms surveyed incurred lost or delayed sales into the European Union costing an average of nearly $2 million per

firm. Taking a proactive approach by transitioning to safer alternatives can not only help businesses remain compliant

with laws and regulations, but also remain competitive in a global marketplace.

Create safer products for consumers and the environment: Transitioning to safer chemicals in the workplace

can also contribute to creating products that are less hazardous for consumers and for the environment. This gives

businesses the opportunity to brand their company with a new, green and innovative image.

This number is derived using the methodology from “Green Chemistry in California: A Framework for Leadership in

Chemicals Policy and Innovation,” (http://coeh.berkeley.edu/docs/news/06_wilson_policy.pdf *(PDF)) to estimate

illness and deaths attributable to workplace chemical exposures.

For more information about the costs associated with workplace injuries and illnesses, see OSHA’s Safety and Health

Topics Page on the Business Case for Safety and Health: https://www.osha.gov/dcsp/products/topics/businesscase/

American Industrial Hygiene Association. (2008). Demonstrating the business value of industrial hygiene: Methods

and findings from the value of the industrial hygiene profession study. Retrieved from:

http://www.aiha.org/votp_new/pdf/votp_report.pdf *(PDF)

University of Massachusetts, Lowell. (2010). CLEAN TECH: An agenda for a healthy economy. Retrieved from:

http://www.sustainableproduction.org/downloads/CleanTechLongFinal2­10_000.pdf *(PDF)

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Home

Why Transition to Safer

Alternatives?

Basics of Informed Substitution

and Alternatives Assessment

Success Stories

Watch Assistant Secretary

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Explore the Steps

Basics of Informed Substitution & Alternatives Assessment

Considering safer alternatives to

hazardous chemicals is not a new

approach. Thinking about safer

alternatives allows employers, workers,

and decision­makers to identify solutions,

rather than continuing to evaluate and

quantify the problem. This approach can

reduce costs and keep businesses

competitive. On the other hand,

continuing to assess a problem has no

economic benefit.

Several terms and phrases are commonly

used to describe this type of solutionsoriented approach to chemical

management.

Informed substitution, replacing

hazardous substances with safer

alternatives, is the goal of a solutionsoriented approach to chemical

management. It involves identifying

alternatives and evaluating their health

and safety hazards, potential trade­offs,

and technical and economic feasibility. A

safer alternative is an option that is

less hazardous for workers than the

existing means of meeting that need. Sometimes, this means choosing the option of not continuing an activity

altogether; this also may include using chemical substitutes or product or process redesigns that completely eliminate

the need for specific hazardous chemicals. Informed substitution is the goal of the seven step process presented by

OSHA in this toolkit.

Substitution planning is a process to systematically set goals and priorities to reduce hazards, develop a chemical

use inventory, evaluate alternatives, identify preferred alternatives, and implement alternatives. Taken together, steps

1­7 outline a substitution planning process.

An alternatives assessment is a process for identifying, comparing, and selecting safer alternatives for hazardous

chemicals on the basis of their hazards, performance, and economic viability. An alternatives assessment is a key

component of a substitution planning process and is used in the evaluation and comparison of alternatives.

A number of tools and methods have been developed to evaluate hazards, performance, and economic viability as part

of an alternatives assessment. For example, comparative chemical hazard assessment tools provide a method to

compare chemical alternatives on the basis of their chemical hazards. Steps 3­5 of the toolkit – identifying, assessing,

comparing, and selecting the alternatives – include tools employers and workers can use to perform an alternatives

assessment.

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Further Resources

Background

Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ). Practical Chemical Management Toolkit . This toolkit

provides a step­by­step process for identifying and assessing chemical hazards, managing the risks associated with the

use of chemicals, and planning and preparing for any emergencies involving chemicals.

Interstate Chemicals Clearinghouse (IC2). IC2 Safer Alternatives Assessments . This website outlines a protocol for

conducting safer alternatives assessments and provides a set of resources to draw from when performing an

alternatives assessment.

Ontario Toxics Reduction Program. Reference Tool for Assessing Safer Chemical Alternatives . This reference tool

provides support and guidance for government, industry, and other stakeholders to identify and consider safer

alternatives.

Organization for Economic Co­operation and Development. Current Landscape of Alternatives Assessment Practice: A

Meta­Review . This document summarizes the literature on substitution of chemicals of concern, with a focus on the

current landscape of substitution practice in OECD member countries.

Frameworks

BizNGO. BizNGO Chemical Alternatives Assessment Protocol . *(PDF) This resource is a decision framework for

substituting chemicals of concern to human health or the environment with safer alternatives.

BizNGO. The Guide to Safer Chemicals . This resource is a hands­on guide for downstream users of chemicals that

charts pathways to safer chemicals in products and supply chains.

Chemical Commons. Principles for Alternatives Assessment . This framework includes six principles for alternatives

assessment that guide a process for well­informed decision making that supports successful phase­out of hazardous

products, phase­in of safer substitutes, and elimination of hazardous chemicals where possible.

European Commission. Minimizing Chemical Risk to Workers' Health and Safety Through Substitution . This report

presents a systematic, yet flexible, risk­based process for chemical substitution in the workplace.

German Federal Environment Agency (Umweltbundesamt). Guide on Sustainable Chemicals . This guide assists in the

selection of sustainable chemicals by providing criteria to distinguish between sustainable and non­sustainable

substances.

German Federal Institute for Occupational Safety and Health (BAuA). Technical Rules for Hazardous Substances—

Substitution (TRGS 600) . This guidance provides a framework for identifying and evaluating substitutes and

establishes criteria for assessing and comparing the health risks, physicochemical risk, and technical suitability of

identified alternatives.

Interstate Chemicals Clearinghouse (IC2). Guidance for Alternatives Assessment and Risk Reduction . This document

provides background information on what is found in and how to conduct an alternatives assessment.

Lowell Center for Sustainable Production. Alternatives Assessment Framework . This resource provides a framework

for the quick assessment of safer and more socially just alternatives to chemicals, materials, and products of concern.

National Institute for Occupational Safety and Health. Prevention through Design (PtD). This website describes the

concept of Prevention through Design, a framework for addressing occupational safety and health needs in the design

process to prevent or minimize the work­related hazards and risks associated with the construction, manufacture, use,

maintenance, and disposal of facilities, materials, and equipment.

National Research Council. A Framework to Guide Selection of Chemical Alternatives . This report presents a decision

framework for assessing potentially safer substitute chemicals and demonstrates the use of the framework with two

case studies.

U.S. EPA Design for the Environment Program. Alternatives Assessments. This website describes the key steps to

conducting an alternatives assessment.

U.S. EPA. Greening Your Purchase of Cleaning Products: A Guide for Federal Purchasers. This website highlights

guiding principles that provide a framework purchasers can use to make environmentally preferable purchases.

Methodologies

Massachusetts Toxics Use Reduction Institute. Five Chemical Alternatives Assessment Study . This study presents a

methodology for assessing alternatives to chemical of concern based on performance, technical, financial,
environmental, and human health parameters.

U.S. EPA Design for the Environment Program. Cleaner Technologies Substitutes Assessments. This publication

presents the methods and resources needed to conduct a Cleaner Technologies Substitutes Assessment (CTSA), a

methodology for evaluating the comparative risk, performance, cost, and resource conservation of alternatives to

chemicals currently used by specific industry sectors.

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accessing DOC, EPS, GIF, MP4, PDF, PPT or XLS documents.

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Transitioning to Safer Chemicals:

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Why Transition to Safer

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Basics of Informed Substitution

and Alternatives Assessment

Success Stories

Watch Assistant Secretary

Michaels' Introductory Video

Explore the Steps

Success Stories

Many organizations have already realized worker health and safety benefits, increased productivity, and saved

money by reducing the use of hazardous chemicals and implementing safer alternatives.

Safer Processes

Designing a Safer Process for Chemical Manufacturing

DuPont Corporation

DuPont is a large chemical manufacturer that makes products for many industries — agriculture, marine,

healthcare, energy, food and beverage, and mining, to name a few. Methyl isocyanate (MIC) is a highly toxic,

irritating and flammable chemical that is commonly used to produce the carbamate pesticide methomyl; it is often

manufactured in a separate production unit at facilities and stored in large pressure vessels. Following the 1984

deadly MIC release from the Union Carbide facility in Bhopal, India — where approximately 30 metric tons of toxic

MIC escaped from a storage tank into the atmosphere in less than an hour killing thousands and injuring hundreds

of thousands — DuPont implemented a new technology for producing methomyl at its plant in LaPorte, Texas.

DuPont converted the less acutely toxic chemical methylformamide into MIC as a vapor­phase (rather than liquid) on

an as­needed basis, which was immediately consumed in a subsequent reaction, leaving very little MIC in the

system at one time and removing phosgene from the production process. DuPont's method reduced worker handling

of several toxic chemicals; eliminated the need to transport, store, and transfer MIC and phosgene; and addressed

lifetime cost issues.

Sources

The National Academies (2012). The Use and Storage of Methyl Isocyanate (MIC) at Bayer CropScience. Retrieved

from: http://www.nap.edu/openbook.php?record_id=13385&page=83

U.S. Chemical Safety and Hazard Investigation Board (2011). Pesticide Chemical Runaway Reaction Pressure Vessel

Explosion. Retrieved from: http://www.csb.gov/assets/1/19/Bayer_Report_Final.pdf

Safer Chemicals

Transitioning to Safer Chemical Alternatives in Wire and Cable

Products

AlphaGary Corporation

AlphaGary specializes in the design and development of plastic compounds for a variety of applications. Internal

company initiatives combined with external factors, including European and Massachusetts laws, influenced

AlphaGary to collaborate with its supply chain partners and other stakeholders to investigate less toxic alternatives

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for lead compounds used as heat stabilizers in formulations for wire and cable

products. Investments in research and internal capacities for product design,

evaluation, and testing resulted in: the development of new lead­free product

formulations that maintained quality and performance; reduced risk to workers

handling lead­based materials; reduced medical monitoring and personal exposure

monitoring for lead; improved product development capabilities; streamlined product

certification processes; and enhanced the company’s competitive global supply

position.

Transitioning to Safer Chemical Alternatives in Laundry Detergents

Washing Systems, LLC

Washing Systems, LLC is one of the most innovative chemical suppliers to

the laundry industry in the U.S. and Canada. In 2005, the company’s

leadership made a critical decision to focus 100% of all research and

development on new chemical technologies that exhibit safer,

environmentally sustainable profiles. The initiative to develop a new "green"

line of detergents became an immediate outgrowth of this decision and

focused heavily on their use of nonylphenol ethoxylates (NPEs). The

challenge of this initiative was set in seven critical project objectives:

1. Detergents must be 100% free of NPEs

2. Detergents must be used as one for one direct replacements for NPE detergents

3. Detergents must have the same ounce for ounce cost to NPE detergents

4. Detergents must exhibit the same “end­use” cost to the customer as NPE detergents

5. Cleaning performance must be equal to or improved over NPE detergents

6. Wash formulas must maintain the same “rapid rate” wash formulas as NPE detergents

7. Detergents must be certified by the EPA’s Design for Environment (DfE)

At the end of 2007, Washing Systems’ R&D successfully met each of these objectives. In 2008, Washing Systems

launched a new line of NPE­Free detergents into the commercial laundry market. Today, the success of this R&D

project is evident to all Washing Systems customers, as all are 100% free of NPEs. This effort has reduced over 4.5

million lbs of NPEs/year from being discharged to the environment.

In addition to eliminating the use of NPEs in its products, Washing Systems has eliminated the use of butyl cellosolve

and petroleum hydrocarbon based solvents in detergents, eliminated the use of phosphates and

ethylenediaminetraacetic acid (EDTA) within the laundry builders, and reduced the petroleum hydrocarbon based

solvents by 46% in other specialty products. The new formulations are not only less hazardous to workers and the

environment, but also provide economic and efficiency benefits to Washing System’s customers (i.e., reduced water

and energy usage, increased wash productivity, lower chemical costs).

To identify alternatives, the company’s scientists and engineers use CleanGredients , a database of safer cleaning

products ingredients that meet specific health and environmental criteria. The company also uses the

GreenScreen , a comparative chemical hazard assessment method, to evaluate and compare hazards of alternative

chemicals. Washing Systems carries out extensive in­house performance testing as well as field trials in customers’

facilities to ensure that the alternatives demonstrate superior levels of cleaning quality and operational performance

compared to the chemistry it replaces.

Safer Products

Systematically Evaluating Hazardous Products and Transitioning to

Safer Alternatives

Seattle City Light

Seattle City Light, one of the nation’s largest municipally­owned electric utilities, has successfully developed and

implemented a chemical use reduction policy and procedure for moving to safer products and processes. Under this

policy, the utility is required to reduce the overall use of hazardous materials to the extent practical, to phase out

the use of products that pose human health or environmental risks, and to increase the use of safer alternatives. To

implement the policy, Seattle City Light reviews new products, as well as its existing chemical inventory, based on

chemical acceptability criteria developed by the utility. The approval process uses this hazard evaluation to place the

product into tiers and determine whether it should be classified as a preferred product. Only products that have

made it through this approval process can be utilized by the utility in its operations. After the selection and

implementation of preferred alternatives, Seattle City Light frequently conducts evaluations of product performance

in particular applications, collaborating with workers to determine the impact of the alternatives on shop floor

operations.

®

TM
Through this ongoing process, the utility has been able to identify and transition to

preferred products in a variety of applications. For example, when Seattle City Light

reviewed its welding operations in steel shops, the utility identified a substitute for the

use of thoriated tungsten electrodes, which expose workers to radiation. Seattle City

Light utilized an alternatives assessment developed by the American Welding Society

to select and replace these electrodes with ones containing lanthanum, a less toxic

alternative that can be used in a wide range of applications. This move reduced

worker exposures, as well as met the performance needs of the operation, without

significantly increasing costs.

Transitioning to Safer Alternatives in Bathtub Stripping

Bathcrest of Seattle and the Seattle Bathtub Guy

The Washington State Department of Labor and Industries’ Safety and Health Assessment and Research for

Prevention (SHARP) Program worked with two small businesses exploring alternatives to methylene chloride­based

paint strippers for bathtub refinishing.

Bathcrest of Seattle began investigating

alternatives to methylene chloride­based

paint strippers after Washington­OSHA

assessed significant fines for their use of

Klean­Strip Aircraft Remover during

bathtub stripping. Bathcrest tested

several paint strippers, including Turco

6776­LO (benzyl alcohol and formic acid),

Ready­Strip Plus Safer Paint & Varnish

Remover (dimethyl glutarate and Nmethylpyrrolidone (NMP)) and Smart

Strip (benzyl alcohol). Due to hazard,

availability, and performance concerns,

Bathcrest selected Smart Strip. Selecting

and implementing this alternative is also

supported by research that tested

methylene chloride­free paint strippers

and concluded that benzyl alcohol based

products are the best choice. While using

Smart Strip, Bathcrest successfully and

competitively stripped over 1,000 tubs

within a two year period.

The Seattle Bathtub Guy is a successful

small bathtub refinishing business that

uses scraping and sanding to prepare

bathtubs instead of chemical paint

strippers. In most cases, scraping and

sanding only the damaged sections of the

bathtub’s finish is all that is necessary—

the full removal of the top coat is needed

only a small fraction of the time. The

Seattle Bathtub Guy’s experience has

found scraping and sanding to be a

faster, simpler, safer, and less expensive

method for stripping bathtubs. By using

this process, the business has been able

to eliminate the odor and health risks

associated with chemical paint strippers,

prepare surfaces more quickly (1 to 1 1⁄2

hours compared to chemical paint

strippers that require time and multiple

applications to work), and avoid the costs of complying with the methylene chloride standard (including medical

surveillance).

Sources

Washington State Department of Labor & Industries. Successful Bathtub Stripping with Benzyl Alcohol as an

Alternative to Methylene Chloride (MC). Retrieved from:

http://www.lni.wa.gov/Safety/Research/Files/MCHazAlertBenzylAlcoholAlternative.pdf *(PDF)
Has your business successfully implemented safer alternatives to hazardous chemicals, materials,

products, or processes? Share your story with us.

Note: Any references to companies or other non­governmental entities within this guide are only for information

purposes and should not be interpreted as an official endorsement of those entities, their products or services by the

U.S. Department of Labor.

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Institute for Research and Technical Assistance. Methylene Chloride Consumer Product Paint Strippers: Low­VOC,

Low Toxicity Alternatives. Retrieved from:

http://www.irta.us/Methylene%20Chloride%20Consumer%20Product%20Paint%20Strippers%20REPORT%20ONLY.pdf

*(PDF)

Washington State Department of Labor & Industries. Successful Bathtub Stripping Using Sanding as an Alternative to

Methylene Chloride. Retrieved from: http://www.lni.wa.gov/Safety/Research/Files/BusinessProfileSanding.pdf

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Transitioning to

Safer Chemicals

STEP 1

Engage

STEP 2

Inventory &

Prioritize

STEP 3

Identify

STEP 4

Assess &

Compare

STEP 5

Select

STEP 6

Test

STEP 7

Evaluate

Home

Why Transition to Safer

Alternatives?

Basics of Informed Substitution

and Alternatives Assessment

Success Stories

Watch Assistant Secretary

Michaels' Introductory Video

Explore the Steps

Key Example

Goal Setting

Step 1: Form a Team to Develop a Plan

Creating a systematic change in chemical use is best accomplished by establishing a team to develop a work plan and

set goals. This step will help you develop your plan.

Key Questions

How will workers be involved in the team and throughout the planning process?

Who should be involved in developing the work plan and setting goals for transitioning to safer chemicals (e.g.,

managers, supply chain partners, customers, marketers, health and safety committee members, occupational

health nurse or physician, occupational health consultant)?

What goals should be included in the plan? Consider specific goals such as eliminate carcinogens, reduce the

use of hazardous chemicals by a certain percentage in a set number of years, substitute chemicals of concern

from government or sector lists, etc.

What policies, tasks, responsibilities, deadlines should be included in the plan?

What particular drivers should you be aware of in developing the plan (existing or new laws, consumer

pressures, new science)?

How will external stakeholders be involved?

Assemble an internal team to take responsibility for developing the work plan for transitioning to safer chemicals.

Consider who should be involved in the team (e.g., existing safety and health committee members, workers, managers,

union representatives). It is important to involve workers that perform various functions in your workplace (e.g.,

designers; engineers; and service, maintenance, and research and development staff). Also identify any external

stakeholders who should be included in the planning process (e.g., designers; engineers; service, maintenance,

research and development staff).

There is no one­size­fits­all method for developing a work plan for transitioning to safer chemicals. Setting goals is an

important part of a work plan; these goals could be long­term, industry­specific, or chemical­specific. Your plan also

may include company­ or industry­specific policies on safety or chemical management, targets for chemical use, and

approaches for prioritizing and managing chemical hazards. This will help make decisions easier when comparing

different types of hazards and deetermining how hazards should be prioritized and evaluated.

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There are a variety of examples of goals for chemical management. These range from long­term goals, to

industry­specific goals, to chemical­specific goals. Some examples include:

"To act responsibly, Dell believes that if reasonable scientific grounds indicate that a

substance (or group of substances) could pose significant environmental or human

health risks, then Dell should avoid using the substances."

— Dell’s Chemical Use Policy

"Where there are reasonable grounds for concern that a chemical used in our product

could be harmful to human health or the environment, we will always take appropriate

precautionary measures."

— Boots Chemical Working Group

"We envision and strive to create a world in which all consumer products are produced

using Sustainable Chemistry practices, ultimately using inherently safer chemicals and

reducing or eliminating hazardous chemicals, in order to preserve human health and a

clean environment."

— Outdoor Industry Association Chemical Management Working Group

"Commitment to collaborate and lead the apparel and footwear industry towards zero

discharge of hazardous chemicals for all products across all pathways in our supply

chains by 2020."

— Footwear and Apparel Industry’s Roadmap to Zero Discharge of Hazardous Chemicals

"Reduce the use of carcinogens or mutagens at the place of work, in particular by

replacing it, in so far as is technically possible, by a substance, preparation or process,

which under its condition for use, is not dangerous or is less dangerous to worker’s

health or safety."

— EU Carcinogens and Mutagens Directive

Key Example

Developing a Work Plan

The National Pollution Prevention Roundtable’s 2025 Safer Chemistry Challenge Program established a seven

step program that companies can use to eliminate or reduce chemicals of concern. Setting performance goals

and creating an action plan are key elements of the program. As such, the program provides a simple and useful

method for visualizing and operationalizing a company’s goals and work plan.

Sample Work Plan

Chemical

Reduction

Goal

Achievments

to Date

Action

Steps Timeline Metrics

Alternative

Assessment

Tools Used

Methylene

Chloride

100% Have begun to

research

alternatives

Identify

Alternative

Test

alternative

Convert to

alternative

solvent

December

2011

March 2012

May 2012

Pounds per

Year (Lb/yr)

Green

ScreenTM;

EPA
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Transitioning to

Safer Chemicals

STEP 1

Engage

STEP 2

Inventory &

Prioritize

STEP 3

Identify

STEP 4

Assess &

Compare

STEP 5

Select

STEP 6

Test

STEP 7

Evaluate

Home

Why Transition to Safer

Alternatives?

Basics of Informed Substitution

and Alternatives Assessment

Success Stories

Watch Assistant Secretary

Michaels' Introductory Video

Explore the Steps

Step 2: Examine Current Chemical Use

To identify targets for informed substitution, you need to know how you use chemicals in your workplace and the

hazards associated with each of these chemicals. This step will help you examine your current chemical use.

Key Questions

For each chemical, consider:

Where is the chemical being used?

What function does the chemical perform?

Is the chemical necessary in the process or product? Could the chemical be eliminated without adversely

affecting product or process performance?

What are the hazards associated with the chemical and how could its use harm workers?

How are workers potentially exposed to the chemical (i.e., during manufacturing of the chemical or product,

when using a product containing chemicals, when applying the chemical in a service industry, or during

chemical disposal)?

To identify priorities, consider:

What hazards should be eliminated or reduced first?

What uses of chemicals are of greatest concern?

What potential chemical exposures to workers are of greatest concern?

Could a chemical or process change help improve workplace safety and health?

Are the identified priorities consistent with the work plan for transitioning to safer chemicals?

First, you should work with your team to develop an up­to­date inventory of all the chemicals used in your workplace,

including chemicals used during production, performing service tasks, and during cleaning and maintenance operations.

This should include information about how the chemical is made, handled, stored, disposed, or transported. You should

also describe the function the chemical performs, as well as the physical form of the chemical, the frequency and

duration of the chemical use, and the quantity of the chemical used. It is important to understand whether the use of

the chemical is actually necessary in your operation. The safety data sheets (SDSs) required for hazardous chemicals

under OSHA's Hazard Communication standard (29 CFR 1910.1200(g)(1)) can provide a helpful starting point for your

inventory; however, ensure your inventory is updated so that it includes all uses of all chemicals in your workplace, and

ensure your supplier has provided you with a manufacturer’s SDS for each chemical. Incomplete SDSs or SDSs that do

not include information about ingredients below a certain concentration are good examples of why all chemicals, not

just those classified as "hazardous,"" should be inventoried in this step. The chemical use inventory can be as simple as

a list or spreadsheet or as sophisticated as a process flow diagram. A process flow diagram graphically illustrates the

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Key Resource

Chemical Hazard and Alternatives Toolbox

(ChemHAT)

ChemHAT helps workers and employers understand whether a chemical

can impact their health and whether safer alternatives exist.

The chemical information provided by ChemHAT allows you to rapidly

understand the types of health effects related to a chemical and the

strength of those effects. This information can help you examine your chemical use and identify which hazards

you should eliminate or reduce first. ChemHAT also provides information on existing case studies of safer

alternatives. This information can help you quickly understand where the potential for substitution exists and

what alternatives you should consider evaluating further.

Key Resource

Restricted and Priority Substance Database

Lists of restricted and priority substances can provide a good starting point

for identifying the most hazardous chemicals in your workplace. These lists

generally include chemicals that are currently restricted by a government

body anywhere in the world, as well as chemicals of concern that are not

yet regulated. Through the SUBSPORT's Restricted and Priority Substance

Database , you can simultaneously search 32 lists of substances that are

legally or voluntarily restricted or are recommended for restriction due to their hazards. The database includes

lists from international agreements, EU regulatory lists, governmental lists, non­governmental organization and

trade union lists, and internal company lists.

Key Resource

RISCTOX

Databases that compile multiple sources of chemical information can help

you quickly understand the hazards associated with the chemicals used in

your workplace. RISCTOX is a database of over 100,000 chemical

substances that provides clear, organized, and concise information about

health and environmental risks. The database includes data on a

substances’: classification by the Globally Harmonized System of

Classification and Labeling of Chemicals (GHS), specific health risks, specific environmental risks, and

environmental and health­related regulations.

chemical inputs, products, and non­product output streams for a particular manufacturing process and may point out

upstream changes that could help reduce or eliminate the use of hazardous chemicals. While it may be easier to

compile information about chemicals used in the processes in your workplace, it is also important to know which

chemicals are contained in products used by workers and the hazards associated with them. Workers in nonmanufacturing industries – such as cleaners, plumbers, floor installers, and construction workers –encounter chemicals

in such products on a regular basis.

Next, you should identify the hazards associated with the chemicals used in your workplace. This should be a rapid

evaluation of the hazards using existing resources, rather than an in­depth assessment requiring interpretation of

toxicological test results or other scientific literature. Cross­referencing chemicals in your workplace to those on

restricted substances lists and reviewing the hazard categories listed on safety data sheets can help you identify the

most hazardous chemicals. Other chemical databases, such as ChemHAT and RISCTOX can help you quickly

identify the hazards associated with chemicals you use in the workplace.
Key Resource

European Commission's Prioritization Matrix

The European Commission’s Guidance on Minimizing Chemical Risk to

Workers’ Health and Safety Through Substitution provides a risk matrix

tool that can be used for prioritization. The tool combines a qualitative

evaluation of hazard and exposure potential to identify chemicals that could

be good targets for substitution efforts. The matrix uses hazard categories

found on a Safety Data Sheet to rank the hazard level of the chemical

from1 (low hazard) to 5 (very high hazard). The matrix uses information

about where, how often, and in what way the chemical is used to rank

exposure potential from 1 (low exposure) to 5 (very high exposure) with

regards to working/process conditions, physical properties affecting

exposure, frequency or duration of use, quantity used, and accident

potential. Combining the qualitative hazard and exposure potential scores

allows you to identify chemicals with the highest risk and greatest potential for substitution.

Further Resources

Creating Chemical

Inventories

Massachusetts Department of

Environmental Protection. Toxics Use

Reduction Planning and Plan Update

Guidance. *(PDF) This guidance

describes and provides support for

the toxics use reduction planning

process, presents best management

practices, and shares examples of

actual toxics use reduction successes.

New Jersey Department of

Environmental Protection. Industrial

Pollution Prevention Planning . *

(PDF) This report identifies twelve

steps that can help firms identify and

achieve pollution prevention

opportunities.

NEWMOA. Energy and Materials Flow

and Cost Tracker (EMFACT) . This

software tool helps companies

systematically track materials and

energy use; releases, discharges, and

wastes; and associated costs in ways

that can create value for their

business.

Obtaining Product

Chemical Information

Green Chemistry and Commerce

Council. Meeting Customers’ Needs

Assessing Chemical Hazard

ChemSec. SIN (Substitute It Now!)

List . This database contains 626

chemicals identified as Substances of

Very High Concern based on the

criteria established by the EU chemical

regulation, REACH.

Dutch Ministry of Housing, Spatial

Planning and Environment. Quick Scan

. *(PDF) This is a screening method

that uses existing data, criteria and

decision­making rules to evaluate

substances and place them into

categories of concern based on

hazard.

European Chemicals Agency (ECHA).

Classification and Labeling Inventory

Database . This database contains

classification and labeling information

on REACH notified and registered

substances received from

manufacturers and importers, as well

as the list of EU harmonized hazard

classifications.

Healthy Building Network. Pharos .

This resource includes a chemical and

material library containing over 20,000

substances screened against over 40

authoritative hazard and warning lists.

The library identifies health hazards

IUE­CWA and BlueGreen Alliance.

ChemHAT—Chemical Hazard and

Alternatives Toolbox . This database

provides information on chemical

hazards, uses, exposures, and safer

alternatives.

KEMI­­Swedish Chemicals Agency.

PRIO . This is a web­based tool

intended to facilitate the assessment

of health and environmental risks of

chemicals so that risk reduction

opportunities can be identified and

prioritized.

Ministry of Social Affairs and

Employment of Netherlands.

Stoffenmanager . This is a tool for

small and medium­sized enterprises

to prioritize their health risks to

dangerous substances and to

determine effective control measures.

SUBSPORT. Restricted and Priority

Substances Database . This database

contains 32 lists of substances that

are legally or voluntarily restricted or

are recommended for restriction due

to their hazards.

U.S. Environmental Protection Agency.

ChemView. This web tool displays key

health and safety data on chemicals

While it is important to consider transitioning to safer alternatives for each of the hazardous chemicals used in your

workplace, you do not have to pursue substitution activities for every chemical immediately. Instead, you should work

with your team to identify priorities to maximize the use of limited resources. Chemicals can be prioritized based on

various criteria, including, but not limited to: hazard, exposure, risk, regulation potential, established company policies,

interests of relevant stakeholders, and substitution potential. OSHA 300 logs may also provide helpful information about

what chemical uses and exposures are of greatest concern in your workplace. Setting these priorities could reflect the

larger goals in your work plan for transitioning to safer chemicals or help you further refine your work plan.
for Chemical Data: A Guidance

Document for Suppliers . *(PDF)

This document outlines resources that

can assist suppliers in collecting and

providing chemical information to

their customers.

that may come directly from exposure

to a substance or from chemicals used

or created in its production.

Interstate Chemicals Clearinghouse

(IC2). This State Priority Chemicals

Resource database contains lists of

priority chemicals developed under

various state laws.

ISTAS. RiscTox . This database

provides information about health and

environmental risks for over 100,000

chemical agents.

and provides streamlined access to

EPA assessments, hazard

characterizations, and information on

safer chemical ingredients.

U.S. National Library of Medicine.

TOXNET: Toxicology Data Network.

This database provides information on

toxicology, hazardous chemicals,

environmental health, and toxic

releases.

Accessibility Assistance: Contact OSHA's Directorate of Standards and Guidance at (202) 693­1950 for assistance

accessing DOC, EPS, GIF, MP4, PDF, PPT or XLS documents.

*These files are provided for downloading.

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Transitioning to

Safer Chemicals

STEP 1

Engage

STEP 2

Inventory &

Prioritize

STEP 3

Identify

STEP 4

Assess &

Compare

STEP 5

Select

STEP 6

Test

STEP 7

Evaluate

Home

Why Transition to Safer

Alternatives?

Basics of Informed Substitution

and Alternatives Assessment

Success Stories

Watch Assistant Secretary

Michaels' Introductory Video

Explore the Steps

Identify

Key Resources

Step 3: Identify Alternatives

Identifying alternatives opens up the potential for finding more efficient, safer, and more sustainable solutions. This

step will help you get a clear overview of your different options.

Key Questions

Are there chemical alternatives that have been implemented in similar applications?

Are there material changes or process changes that could replace the use of hazardous chemicals?

Are there other businesses that are also seeking safer alternatives for the same chemical or a similar use of

the chemical? Are there opportunities to collaborate?

After targeting a chemical for substitution efforts, it is important to broadly consider all possible chemical alternatives,

material alternatives, process changes, design changes, technological solutions, or other options to eliminate the

hazardous chemical, even if particular options may be currently infeasible.

When looking for chemical alternatives, material substitutes, or process changes for a particular application/use, it is

best to begin with industry­specific information and case examples about what is currently being used in the market.

From there you can usually identify specific companies that are using alternatives; these companies are often good

resources for identifying other alternatives they may be aware of or have tried. Talking to suppliers, workers, industry

associations, government officials, professional associations, and non­governmental organizations can also provide

information on existing alternatives.

Specific resources have been developed for researching alternatives to hazardous chemicals. These resources include

case studies of substitution (SUBSPORT , CatSub , IFCS ), databases of alternatives (Alternativas (in Spanish

only), CleanGredients , Cleantool ), as well as completed alternatives assessments (Interstate Chemicals

Clearinghouse ). Performing a single search of multiple online resources related to substitution is another rapid way

to identify possible alternatives.

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Case Story Database

SUBSPORT’s Case Story Database provides over 300 substitution examples

as well as information on alternative substances and technologies from

businesses, published reports and other sources. Substances mentioned in

the case stories are evaluated for hazards and screened out of the

database if they are identified as CMRs (carcinogens, mutagens,

reproductive toxicants), PBTs (persistent, bioaccumulative, and toxic

chemicals), endocrine disruptors, neurotoxicants, or sensitization agents.

CleanGredients

CleanGredients is an online database of safer cleaning product

ingredients that is a unique partnership between the nonprofit institute

GreenBlue, the U.S. EPA, and industry. GreenBlue establishes health and

environmental criteria for each chemical ingredient class with the input and

approval of the U.S. EPA’s Design for the Environment Program. The

database lists a variety of chemical ingredient classes necessary for formulators to make their products,

including: surfactants, solvents, fragrances, chelating agents, colorants, enzymes, defoamers, starter

formulations, processing aids, oxidants, polymers, and preservatives and antioxidants. Each of the listed

ingredients is verified by third­party reviewers (NSF International and ToxServices) as meeting the established

environmental and human health criteria. In addition, the database provides supplier contact information, links to

websites, material safety data sheets, and technical fact sheets for each of the listed ingredients. This resource

helps formulators identify ingredients that have potential environmental and human health benefits and helps

suppliers showcase their chemicals with potential environmental and human health benefits.

Additionally, searching recent scientific literature may lead to discoveries of chemicals, materials, or processes that are

being researched for the application, or for similar applications that have the same or similar performance

requirements. The Massachusetts Toxics Use Reduction Institute’s technical research library of pollution prevention

and chemical alternatives resources can help you locate this type of information about alternative chemicals, materials,

products, and processes.

Where no alternatives exist, consider partnering with other businesses or trade associations to initiate innovative

research on safer products and processes.

Further Resources

Case Studies

Danish Working Environment

Authority. CatSub . This database is

a catalog of more than 300 case

stories describing successful

substitutions with less hazardous

chemicals.

Intergovernmental Forum on

Chemical Safety. Substitution and

Alternatives Case Studies, Examples

and Tools . This resource provides

case studies and examples for

selected chemicals and chemical

categories.

Massachusetts Office of Technology

Assistance. OTA Case Studies. This

website provides links to technology

case studies that profile actual

applications of pollution prevention

technologies and processes that

Databases of Alternatives

Cooperation Centre Hamburg.

Cleantool . This database highlights

best practices for the cleaning of

metal surfaces and provides

information about less hazardous

parts cleaning, metal surface

cleaning, component cleaning, and

degreasing.

GreenBlue. CleanGredients . This

is an online database of cleaning

product ingredient chemicals,

providing verified information about

the environmental and human health

attributes of listed ingredients.

ISTAS. Alternativas de Sustitución

(Spanish) . This database provides

information on alternative chemicals,

technologies, and processes, as well

as case examples of substitution.

Completed Alternatives

Assessments

Institute for Research and Technical

Assistance. Reports . This website

provides links to completed

alternatives assessments on a variety

of topics.

Interstate Chemicals Clearinghouse

(IC2). Examples of Alternatives

Assessments . This website provides

links to completed alternatives

assessments on a variety of topics.

U.S. EPA Design for the Environment

Program. Alternatives Assessments.

This website provides links to

completed alternatives assessments

on a variety of topics.

®

®

®
businesses, municipalities, and other

toxics users across Massachusetts

have implemented.

Massachusetts Toxics Use Reduction

Institute. Toxics Use Reduction Case

Studies . This website provides links

to documents describing actual

applications of toxics use reduction in

a variety of industry sectors.

SUBSPORT. Case Story Database .

This database provides substitution

examples, as well as information on

alternative substances and

technologies from enterprises,

published reports and other sources.

Massachusetts Institute of

Technology. Green Chemical

Alternatives Purchasing Wizard .

This database is designed to provide

easy and quick access to information

about available chemical alternatives

to hazardous solvents.

Massachusetts Toxics Use Reduction

Institute. CleanerSolutions Database

. This database provides

information about safer alternatives

to hazardous solvents for surface

cleaning.

U.S. EPA Design for the Environment

Program. Safer Chemical Ingredients

List. This list contains chemicals that

meet the criteria of the Design for the

Environment Safer Product Labeling

Program.

U.S. EPA Design for the Environment

Program. Publications. This website

provides links to completed cleaner

technologies substitutes assessments

on a variety of topics.

Scientific Literature

Massachusetts Toxics Use Reduction

Institute. TURI Library . This library

focuses on information related to

toxics use reduction. Its online public

access catalog describes over 14,000

documents and provides links to

documents freely available on the

Web.

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Telephone: 800­321­OSHA (6742) | TTY

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Search

A to Z Index |En Español |Contact Us |FAQs |

About OSHA

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Transitioning to

Safer Chemicals

STEP 1

Engage

STEP 2

Inventory &

Prioritize

STEP 3

Identify

STEP 4

Assess &

Compare

STEP 5

Select

STEP 6

Test

STEP 7

Evaluate

Home

Why Transition to Safer

Alternatives?

Basics of Informed Substitution

and Alternatives Assessment

Success Stories

Watch Assistant Secretary

Michaels' Introductory Video

Explore the Steps

Step 4: Assess & Compare Alternatives

Systematically comparing the hazard, cost, and performance of different alternatives will enable you to make an

informed decision. This step will help you assess and compare alternatives.

Key Questions

To prioritize alternatives for further assessment, consider:

What are the performance requirements of the chemical or process?

Do specific alternatives present a high risk to worker safety and health?

When assessing and comparing alternatives, consider:

What health and safety criteria (toxicological and physical properties) need to be compared?

Will workers experience changes to the performance of their work tasks when using the alternative,

including any changes to the use of engineering controls, administrative controls, and PPE? Will workers

experience changes in exposure when using the alternative? Will these changes present new/different

hazards to workers?

What performance criteria need to be compared?

What costs need to be compared?

Prioritize

Once alternatives are identified, it is often necessary to prioritize them for further assessment. Focusing the work on

the most promising alternatives is an effective way to use limited resources and avoid unnecessary research and

evaluation.

Prioritizing alternatives based first on performance can help to narrow the scope of alternatives to those that have the

potential to be effectively implemented in the workplace while maintaining process and product quality. To identify

performance requirements for the chemical, material, or product that you are looking to replace, the planning team

should consider what the chemical, material, or product needs to do and whether there are specific technical and

engineering design constraints. Other functional requirements, such as quality criteria and customer or legal

requirements for technical acceptability should also be considered.

Before further evaluating your options, you may also consider deprioritizing those alternatives that may result in new

hazards or will not substantially improve worker safety and health. You can use existing restricted substances lists ,

authoritative lists of priority chemicals , and lists of chemicals of concern to rapidly identify alternatives that present

worker safety and health concerns, are inconsistent with company goals, or may be subject to legal or consumer

Occupational Safety & Health Administration We Can Help

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Acute Health Hazards

Acute toxicity

Eye damage

Skin damage

Sensitization (e.g., skin, respiratory)

Safety Hazards

Corrosivity

Flammability

Reactivity

Explosivity

Oxidizing properties

Pyrophoric properties

Chronic Health Hazards

Chronic Toxicity

Target Organ Toxicity

Carcinogenicity

Mutagenicity/Genotoxicity

Reproductive Toxicity

Developmental Toxicity

Endocrine Disruption

Neurotoxicity

Immune System Effects

Use Hazards

Physical form of the chemical

Procedural hazards (e.g., open process, direct skin

contact)

Ergonomic hazards

Noise hazards

Vibration hazards

Several existing resources identify hazards that could be included in your evaluation. SUBSPORT’s compilation of hazard

criteria (health, environmental, and physical) provides information about which characteristics are associated with

substances of concern. The EPA’s Design for the Environment Safer Product Labeling Program has also developed

hazard criteria for chemicals used in formulated products. The Massachusetts Toxics Use Reduction Institute’s P2OASys

Tool provides hazard criteria relevant to chemical, material, and process changes in the workplace.

As part of the hazard assessment, it is also important to understand whether alternatives will significantly change

working conditions (i.e., the way in which the chemical is used by workers or the way in which workers are exposed to

the chemical). This will allow you to identify any additional hazards the alternatives may present to workers. Be sure to

consider upstream or downstream hazards to workers – in disassembly, making the new chemical, etc.

A number of tools are available to help you rapidly assess and compare health and physical hazards of identified

alternatives. The Column Model , the Quick Chemical Assessment Tool, and the Green ScreenTM can help assess and

compare health, physical, and environmental hazards of identified alternatives.

Comparative chemical hazard assessment methods and tools rely on the collection of data from a variety of sources.

The U.S. EPA DfE’s Alternatives Assessment Criteria *(PDF) document provides information on data quality

considerations in evaluating and comparing chemical hazards and Clean Production Action’s Green ScreenTM Tool

identifies authoritative and screening data sources for each endpoint evaluated in the tool. While these resources can

help you locate hazard information that is readily accessible, there are many chemicals for which this type of

information is unavailable. In these cases, suppliers can also be a critical source of hazard information.

Key Example

The Column Model

The Institute for Occupational Safety and Health of the German Federation

of Institutions for Statutory Accident Insurance and Prevention (IFA)

developed the Column Model to help small and medium­sized businesses

assess substitute substances on the basis of just a small amount of

information derived from safety data sheets. The model is based on six

hazard categories (acute health hazards, chronic health hazards, fire and

explosion hazards, environmental hazards, exposure potential, and process

hazards), which are divided into different risk levels, ranked from negligible to very high. Users identify the risk

restrictions. While these options should not be the first you evaluate, they should not be completely eliminated from

consideration. If you find, after further research and evaluation, that none of your first choice alternatives will work, you

may decide to reconsider those options that, while having some concerns, could still be safer and healthier for workers

in a particular application.

Assess Hazard

After identifying the most promising alternatives, the hazard, performance, and cost of each alternative should be

assessed and compared. Selecting the relevant hazard criteria is the first step of your evaluation. To improve worker

health and safety, some hazards you might consider for your evaluation include:
level for each substance using the Globally Harmonized System of Classification and Labeling of Chemicals (GHS)

hazard classifications and information about how the substance is used. Preferred substitutes are then identified

by comparing the risk levels in each of the hazard categories. In most situations, alternatives do not have the

lowest risk level in all hazard categories. Users must decide which potential hazards are more relevant for the

workplace where the product is used, taking into consideration the possibilities to control or manage the

different risks.

Key Example

The Quick Chemical Hazard Assessment (QCAT)

Developed by the Washington Department of Ecology, the Quick Chemical

Assessment Tool (QCAT) is designed to help small and medium­sized

businesses evaluate hazards associated with alternatives to toxic

chemicals. QCAT uses a subset of nine high priority hazard endpoints (6

human health effects endpoints, persistence, bioaccumulation, and acute

aquatic toxicity) to identify a level of concern for each chemical being evaluated. This evaluation places

chemicals along a continuum of concern and assigns a chemical one of four possible grades (A, B, C, F). These

results provide a quick and easy method to identify chemicals that are equally or more toxic than the chemical

being reviewed, allowing users to leverage limited resources to rapidly identify chemicals that are not viable

alternatives to the chemical being assessed.

Key Example

The Pollution Prevention Options Analysis System (P2OASys)

The Toxics Use Reduction Institute developed the Pollution Prevention Options Analysis System

(P2OASys ) to help companies determine whether the options they are considering to replace

chemicals, materials, products, or processes of concern may have unforeseen negative

worker, public health, or environmental impacts. Companies using P2OASys input both

quantitative and qualitative data on the chemical toxicity, ecological effects, physical

properties, and changes in work organization as a result of the proposed option. The tool

arrays data on a range of hazards and the chemical under evaluation receives a score, based

on embedded formulae in an excel spreadsheet, for each type of hazard that indicates very

low to very high risk. These scores can then be combined with other information sources and

professional expertise to make decisions on the selection and adoption of alternatives.

Assess Performance

Next, alternatives should be assessed and compared based on their performance. Selecting the relevant criteria is the

first step of your evaluation. To ensure the alternative performs well, some performance parameters you might

consider for your evaluation include:

Physical Properties

Density

Water solubility

Color

Boiling point/melting point

Flash point

Odor

Vapor pressure

Volatility

Viscosity

Size

Performance Characteristics

Durability

Longevity

Maintenance requirements

Energy consumption

Equipment requirements

Tensile strength

Tear strength

Compressibility

Flame retardancy

Accuracy
Weight Resistance to shock/vibration

Noise level

Operating temperature

The relevant parameters may vary greatly from one application to another. Engaging the team, and any other workers,

product designers, and production engineers, can help identify performance needs, as well as technical and engineering

design restraints. You may also need to consult with suppliers and customers not only to identify the critical parameters

for evaluation, but also to gather information about the performance of alternatives under evaluation.

Key Example

Toxics Use Reduction Institute’s Technical Performance Evaluation

As part of its 2006 Five Chemical Study, the Massachusetts Toxics Use Reduction Institute developed a model for

evaluating the technical performance of alternative chemicals, materials, products, and processes. The study

identified application­specific performance parameters that were required for each use of the chemicals under

evaluation – including longevity, key performance requirements, key physical characteristics and key quality

parameters. While applicable performance requirements vary greatly between uses, this evaluation method

provides a good starting point for identifying criteria that should be considered.

Adapted from TURI Alternatives Assessment Process Guidance .

Assess Cost

Finally, alternatives should be assessed and compared based on their cost. While a full cost­benefit analysis of all the

alternative options is quite costly and not essential, it is important to thoroughly consider relevant cost impacts, both

positive and negative, on your company. Completing such an economic analysis will also help you make the business

case for transitioning to safer alternatives. Some costs and benefits that you might consider in your evaluation include:

Direct Costs

Capital expenditures

Operating costs

Material costs

Maintenance costs

Indirect Costs

Supervision and administrative costs

Regulatory compliance costs

Worker health and safety costs (PPE, lost employee

time, etc.)

Waste management expenditures, including

hazardous waste disposal costs

Insurance, rent, taxes

Liability Costs

Penalties and fines

Personal injury

Worker Compensation

Property damage

Clean­up costs

Natural resources damage

Less Tangible Benefits

Increased sales due to improved product quality,

enhanced public image, consumer trust in greener

products, or other effects

Reduced health maintenance costs due to a safer

work environment

Improved worker productivity due to cleaner working

conditions

Increased worker productivity due to improved

employee relations

Adapted from U.S. EPA Cleaner Technology Substitutes Assessment Methodology *(PDF).
Key Example

European Commission’s Cost Assessment

Methodology

The European Commission’s Guidance on Minimizing Chemical Risk to

Workers’ Health and Safety Through Substitution provides a detailed

table to help small and medium­sized businesses identify costs to take into

account. The table includes parameters for evaluating material costs,

equipment costs, safety costs, time related costs, waste costs, and the

costs of risk. This table is also useful for presenting the impacts and

consequences of a substitution to management.

Further Resources

Hazard Criteria

Green Seal. GS­37 Cleaning Products for Industrial and Institutional Use . This standard establishes requirements for

industrial and institutional cleaning products and includes product performance requirements and environmental and

health considerations.

SUBSPORT. Identifying Substances of Concern . This resource presents an overview of the criteria and their definitions

that are most used by different sources to identify substances of concern.

U.S. Environmental Protection Agency. DfE’s Standard and Criteria for Safer Chemical Ingredients. This standard

includes hazard criteria used to define safer chemical ingredients for several categories of formulated products.

Comparative Chemical Hazard Assessment Tools

Clean Production Action. GreenScreen for Safer Chemicals . This is a methodology for comparative chemical hazard

assessment that can be used for identifying chemicals of high concern and safer alternatives.

German Institute for Occupational Safety and Health. Column Model for Chemical Substitutes . This tool helps

businesses make a quick comparison between the risks of different substances and preparations based on information

found on a Safety Data Sheet.

Massachusetts Toxics Use Reduction Institute. Pollution Prevention Options Assessment System (P2OASys) . This tool

helps companies assess the potential environmental, worker, and public health impacts of alternative technologies

aimed at reducing toxics use.

Washington Department of Ecology. Quick Chemical Assessment Tool (QCAT). This is a simplified assessment tool used

to evaluate hazards associated with alternatives to toxic chemicals.

Performance Criteria

Massachusetts Toxics Use Reduction Institute. Alternatives Assessment Process Guidance . This guidance document

provides a methodology for assessing and comparing the performance of alternatives.

Cost Criteria

European Commission. Minimizing Chemical Risk to Workers’ Health and Safety Through Substitution . Appendix 6 of

this guidance document provides a detailed table to help small and medium­sized businesses identify costs to take into

account. This table is also useful for presenting the impacts and consequences of a substitution to management.

Massachusetts Toxics Use Reduction Institute. Alternatives Assessment Process Guidance . This guidance document

provides a methodology for assessing and comparing the cost of alternatives.

TM
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Ontario Toxics Use Reduction Program. Reference Tool for Assessing Safer Chemical Alternatives. *(PDF) This

guidance document provides information on completing an economics assessment as part of an alternatives

assessment.

U.S. Environmental Protection Agency. Cleaner Technology Substitutes Assessment Methodology. *(PDF) This guidance

document provides a methodology for assessing and comparing the cost of alternatives.

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Transitioning to

Safer Chemicals

STEP 1

Engage

STEP 2

Inventory &

Prioritize

STEP 3

Identify

STEP 4

Assess &

Compare

STEP 5

Select

STEP 6

Test

STEP 7

Evaluate

Home

Why Transition to Safer

Alternatives?

Basics of Informed Substitution

and Alternatives Assessment

Success Stories

Watch Assistant Secretary

Michaels' Introductory Video

Explore the Steps

Key Example

Step 5: Select a Safer Alternative

Decisions that thoughtfully weigh the pros and cons of safer alternatives benefit your company and your workforce. This

step will help you organize information on hazard, cost, and performance, as well as evaluate potential trade­offs, in

order to select alternatives that will improve worker safety and health.

Decisions that thoughtfully weigh the pros and cons of safer alternatives benefit your company and your workforce. This

step will help you organize information on hazard, cost, and performance, as well as evaluate potential trade­offs, in

order to select alternatives that will improve worker safety and health.

Key Questions

What are the advantages and disadvantages of each alternative with regard to hazard, performance, and

cost?

What trade­offs exist for each alternative?

How should the various criteria and impacts be weighed to select alternatives that best enhance worker

safety and health?

Are there other considerations to weigh when determining the best option (energy use, water use,

environmental impacts, hazardous waste management, upstream or downstream hazards to workers, etc.)?

Display Results

After gathering information about potential alternative chemicals, materials, products or processes, it is important to

organize the data for each alternative, including information about the data sources, quality, and gaps. Thoughtfully

presenting the data gathered during an alternatives assessment can help facilitate the decision­making process. The

Interstate Chemicals Clearinghouse provides some useful models for arraying data in ways that allow decisionmakers to visualize gaps and identify tradeoffs.

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Key Example

U.S. EPA’s Design for the Environment Program Alternatives Assessments

After completing an alternatives assessment, the Design for the Environment Program compiles hazard data for

each alternative evaluated in order to facilitate decision­making. The results are presented qualitatively by

endpoint and also clarify the origin of the data (i.e. experimental, estimated values, professional judgment).

Display Results

During the selection of alternatives, you should consider the advantages and disadvantages of each alternative with

regards to hazard, performance, and cost, and identify any trade­offs that exist. You may want to develop a table or

spreadsheet that outlines the pros and cons of each option and their importance in the selection process. Or you may

develop some sort of scoring system that weighs different attributes – safety, performance, and cost.

The selection of a preferred alternative should be directly linked to the goals of your organization and your project. You

should consult the team and use your company goals and work plan for transitioning to safer chemicals, as well as any

chemical use policy, to weigh the various hazard, performance, and cost criteria or make decisions regarding tradeoffs. You should also determine whether there are other impacts of the alternatives, including, but not limited to energy

use, water use, environmental impacts, hazardous waste impacts, and upstream or downstream hazards to workers

that are important to consider in your decision.

Worker input is also important during the selection process. It may be helpful to openly discuss any drawbacks and

benefits of the options, as well as practical considerations of implementation, with the team as well as with any other

workers who might be affected by a change.

Once you have selected an alternative for your particular application, you should communicate the decision to all

relevant parties, particularly those who will work with the alternative chemical, material, product, or process. You

should document the decision­making process, including the thought process, assumptions, and rationales used, so the

decision can be clearly explained, justified, and understood by others. Conducting training might be an efficient way to

communicate these changes; trainings may also fulfill legal requirements of communicating hazards to employees,

depending on the alternatives selected.
Key Example

Massachusetts Toxics Use Reduction Institute’s Perchloroethylene Alternatives

Assessment

In its assessment of seven alternatives to the use of perchloroethylene (perc) in drycleaning, the Massachusetts

Toxics Use Reduction Institute developed a table summarizing the comparison of the alternatives and perc,

based on technical, economic, environmental, regulatory and human health criteria. The table uses color coding

to indicate the preferability of alternatives purely from an environmental health and safety perspective.

Adapted from TURI’s Methods and Policy Report—Assessment of Alternatives to Perchloroethylene for the Dry

Cleaning Industry .

Further Resources

Displaying Results

Interstate Chemicals Clearinghouse (IC2). Presenting

Results . This resource provides information and

examples for compiling information from an alternatives

assessment and displaying the results for transparent

decision­making.

Decision­making

Interstate Chemicals Clearinghouse (IC2). Guidance for

Alternatives Assessment and Risk Reduction . This

document includes a decision module that outlines

strategies for evaluating decision criteria and trade­offs.

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Telephone: 800­321­OSHA (6742) | TTY

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Search

A to Z Index |En Español |Contact Us |FAQs |

About OSHA

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Transitioning to

Safer Chemicals

STEP 1

Engage

STEP 2

Inventory &

Prioritize

STEP 3

Identify

STEP 4

Assess &

Compare

STEP 5

Select

STEP 6

Test

STEP 7

Evaluate

Home

Why Transition to Safer

Alternatives?

Basics of Informed Substitution

and Alternatives Assessment

Success Stories

Watch Assistant Secretary

Michaels' Introductory Video

Explore the Steps

Key Example

Pollution Prevention­Occupational Safety and Health Work Site Assessment

Step 6: Pilot the Alternative

Plan the technical and organizational changes needed on a smaller, pilot scale, before fully implementing the

alternative. This step will help you test and evaluate the change in order to identify successes and failures and

recognize long­term impacts or problems.

Key Questions

Does the alternative perform well?

Does the alternative change working conditions?

What training do workers need to safely and effectively use the alternative?

Are there any unforeseen effects or trade­offs of using the alternative?

Is there a secure supply of the alternative?

How could the alternative be implemented on a larger scale?

Before shifting completely to a safer alternative, it is important to apply the change on a smaller scale, especially if you

are making a complex change. For some alternatives, you may need to conduct a field testing program to make sure

the preferred alternative meets your performance expectations and product quality requirements, and that any

unforeseen changes in use patterns or exposure are identified. Performance and quality can be affected in the process

itself, as well as in any related upstream or downstream processes.

To get the best results, it is important to involve the workers who will be impacted by the change. You should discuss

when and how to make the change and ensure that workers are trained and feel comfortable working with the

alternative chemical, product, or process before the testing begins.

During the pilot or field testing of the alternatives, consult and involve workers to assess the performance, cost, and

health and safety impacts on the work environment. It is also important to identify and evaluate any potential

unexpected problems that occur, including any shift in risks or new hazards presented by the alternative (e.g.,

ergonomic, noise, vibration, environmental impacts, fumes and gases formed in the process). You may also consider

developing a job hazard analysis [PDF*] to describe the changes and identify hazards involved with shifting to a safer

alternative. To ensure that the alternative is not negatively impacting workers, you should consult your OSHA 300 logs

to identify any unexpected injuries or illnesses that may be associated with the use of the alternative. Modifications to

the choice of chemical, process or work practice alternatives may be necessary as a result of this pilot testing.

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(P OSH)

Researchers from the University of Massachusetts, Lowell, developed the P OSH strategy for identifying,

implementing, and evaluating pilots of safer alternatives. A key component of this strategy is a work site

assessment survey that can be used before and after piloting a safer alternative to collect information on the

work environment, the materials used in the process, the potential impact of changing materials on the safety

and health of affected workers, the workers’ perceptions of the pilot, and the direct costs associated with the

pilot. The results of this survey can be used to compare worksite changes, evaluate the technical function of the

alternative, and determine whether a full scale implementation of an alternative is appropriate or what changes

are needed to better protect the health and safety of workers.

Adapted from: Quinn et al. 2006. Pollution Prevention—Occupational Safety and Health in Hospitals: Alternatives

and Interventions. Journal of Occupational and Environmental Hygiene, 3: 182­193.

Accessibility Assistance: Contact OSHA's Directorate of Standards and Guidance at (202) 693­1950 for assistance

accessing DOC, EPS, GIF, MP4, PDF, PPT or XLS documents.

*These files are provided for downloading.

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Telephone: 800­321­OSHA (6742) | TTY

www.OSHA.gov

2

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Search

A to Z Index |En Español |Contact Us |FAQs |

About OSHA

OSHA Newsletter RSS Feeds

Transitioning to

Safer Chemicals

STEP 1

Engage

STEP 2

Inventory &

Prioritize

STEP 3

Identify

STEP 4

Assess &

Compare

STEP 5

Select

STEP 6

Test

STEP 7

Evaluate

Home

Why Transition to Safer

Alternatives?

Basics of Informed Substitution

and Alternatives Assessment

Success Stories

Watch Assistant Secretary

Michaels' Introductory Video

Explore the Steps

Step 7: Implement and Evaluate the Alternative

This step will help you develop a plan to implement the alternative at full scale, monitor the impacts, and continue to

improve the process.

Key Questions

Are workers benefiting from using the alternative?

Have customers, supply chain partners, or others provided any feedback?

How can the use of the alternative be improved?

After you successfully test the alternative on a small scale, you should plan the technological and organizational

changes necessary to implement substitution at full capacity. This includes: developing a step­by­step plan for

implementation; documenting the implementation plan; deciding who should be involved in implementation;

communicating the plan to workers; and developing and performing the necessary training. The team should regularly

communicate with workers throughout this process, which will help identify practical issues with implementation and

contribute to problem solving.

Monitoring and evaluating the full implementation of the alternative will help ensure that it meets your expectations.

This may include tracking the actual impacts on: worker health and safety; performance and efficiency of the tasks or

processes; sales; and services. This evaluation may also include periodic assessments of hazards, discussions with

workers about the impacts of the transition, and evaluations of benefits and any changes in productivity or sales. Once

you’ve effectively implemented a safer alternative, you can share your story through our website.

It is also important to keep yourself informed of any new alternatives. There may be safer, better performing, less

costly innovations coming on the market in the future that would benefit your operation.

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