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National Science and Technology Council Releases Sustainable Chemistry Report

Sept. 15, 2023
The National Science and Technology Council published an important report identifying challenges and outlining a strategy to improve adoption of sustainable chemicals.

Sustainable chemistry has become more central to business success than ever. Societal preferences and climate change implications are pressuring product manufacturers to develop, use and process sustainable chemicals. This trend is here to stay, and cultural, legal and regulatory drivers accelerating this trend are growing exponentially.

On August 3, 2023, the Joint Subcommittee on Environment, Innovation, and Public Health Sustainable Chemistry Strategy Team (ST) of the National Science and Technology Council (NSTC) published its “Sustainable Chemistry Report: Framing the Federal Landscape.” The report is an essential read, and here’s why.

The 2021 National Defense Authorization Act (NDAA) included the establishment of an interagency group led by the White House Office of Science and Technology Policy (OSTP) to coordinate federal programs and activities in support of sustainable chemistry, which led to this report.

The report provides a high-level overview of relevant topical areas around sustainable chemistry and identifies gaps and opportunities. Following the report, the ST will develop a strategic plan for how the federal government can leverage these opportunities to make significant progress in addressing the identified data gaps.

Key Elements of the Report

The report describes the state of federal sustainable chemistry activities and the scientific challenges and hurdles to improving the sustainability of chemistry. To reach the NDAA’s mandates, the report:

  •  Proposes a consensus definition of sustainable chemistry;
  • Proposes a working framework of attributes characterizing and considerations for evaluating sustainable chemistry;
  • Assesses the status of sustainable chemistry in the United States, including its applicability and utility in key sectors of the economy, key technological platforms, commercial priorities, global priorities, workforce development and education, current innovative trends and barriers to innovation; and
  • Summarizes the federal regulations relevant to sustainable chemistry.

The report defines sustainable chemistry as “the chemistry that produces compounds or materials from building blocks, reagents and catalysts that are readily available and renewable, operates at optimal efficiency, and employs renewable energy sources; this includes the intentional design, manufacture, use, and end-of-life management of chemicals, materials and products across their lifecycle that do not adversely impact human health and the environment while promoting circularity, meeting societal needs, contributing to economic resilience and aspiring to perpetually use elements, compounds and materials without depletion of resources or accumulation of waste.”

To progress sustainable chemistry research and development, the report emphasizes a need for coordination between the federal government and state and local entities, as well as outreach activities that engage or inform the public. It also suggests collaboration with international partners, stressing it’s critical for economic and national security. According to the report, the strategic areas identified provide a roadmap for sustainable chemistry activities that, when addressed, will generate actionable information to guide federal agencies and sustainable chemistry collaborators and partners.

The capabilities and approaches developed in response to the report should lead to a holistic treatment of sustainable chemistry. The ST will collaborate with stakeholders, collaborators and numerous partners to generate information that will guide sustainable chemistry standards and metrics, decarbonization, circularity and methods for assessing sustainable chemistry. It will also fuel other innovative public health actions and help the United States realize its vision of clean drinking water and air and safe food for all.

Discussion

Stakeholders cheering the concept of sustainable chemistry will applaud OSTP’s preparation and release of this strategic plan. It lays out a bold and ambitious vision for advancing sustainable chemistry. Implementing this plan will require a sustained effort across the federal government over a long period, but the goal is an important and essential one that justifies the effort.

The report calls out the Toxic Substances Control Act (TSCA) as a key regulatory authority that overlaps with sustainable chemistry. The report focuses narrowly on the EPA’s effort to regulate existing chemicals as a potential driver but neglects to discuss concerns regarding its TSCA Section 5 new chemicals review program that greatly inhibits commercial adoption of sustainable chemicals. Denying sustainable new chemicals means manufacturers and processors would be forced to rely on less sustainable, existing chemicals unlikely to be reviewed under TSCA Section 6 for decades.

As the strategy is implemented, the EPA must consider sustainability characteristics in its new chemicals review. Stakeholders in the sustainable chemical area and others aligned with enhancing the TSCA new chemicals review process are urged to read the report and engage in developing the strategy.

About the Author

Lynn L. Bergeson, Compliance Advisor columnist

LYNN L. BERGESON is managing director of Bergeson & Campbell, P.C., a Washington, D.C.-based law firm that concentrates on conventional, biobased, and nanoscale chemical industry issues. She served as chair of the American Bar Association Section of Environment, Energy, and Resources (2005-2006). The views expressed herein are solely those of the author. This column is not intended to provide, nor should be construed as, legal advice.

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