To protect us from hazardous chemical exposure, a focus on the most problematic classes of chemicals and product groups will continue. The eventual result should be an evolution of products that are less dangerous in our homes, business workplaces and the environment.
By David Nightingale, CHMM, S.C.

When introducing someone to the concept of household hazardous waste (HHW) management, I often say that HHWs are generally “those things around your home that you don’t want to drink or take a bath in and are often found under your kitchen sink, in your basement or garage.” Although not very scientific, people usually get that concept readily. That characterization of household hazardous waste can give the impression that these household chemicals are easily compartmentalized and we are safe from exposure and negative impacts. Not true.

HHW and Household Poisonings
Poison control centers across the U.S. show us every year that we do not adequately protect ourselves and our children from exposure to dangerous household chemical products. The latest,Annual Report of the American Association of Poison Control Centers’ National Poison Data System showed that the more serious reported outcomes, including death, were up 4.61 percent since the year 2000. More than 2.1 million human exposures were logged by U.S. poison control centers in 2019, including documentation of 2,619 deaths. The top three classes of substances reported in 2019 were analgesics (pain relief medicines, over-the-counter and prescription), household cleaning products and cosmetics/personal care products.1 By far, the largest exposure age group reported were for children five years old and younger, at 43 percent of all reported exposures.2

These annual poison control center statistics have consistently shown over many years that young children in the home are disproportionately at risk from common types of household chemicals—almost half of all reported exposures. This has been one of the persistent public health safety drivers for HHW collection programs. In most cases, these poisonings represent what toxicologists refer to as acute exposures, which simply means a short-term exposure and related short-term response. When HHWs are removed from the home, the potential for these acute exposures is mitigated.

Chronic Toxic Exposures
On the other hand, there are chronic exposures and chronic effects or responses. Chronic exposures are often repeated low dose exposure to toxic materials over longer periods of time, weeks, months or years. The negative effects can take longer to occur or accumulate before symptoms are realized—sometimes resulting in permanent damage or disease. In some cases, this is described as chemical sensitivity syndrome or multiple chemical sensitivity.

For example, asbestos was commonly used as an insulating material for many decades in ships, buildings and abrasive materials. When airborne asbestos fibers are breathed into the lungs it can result in asbestosis, lung cancer and other diseases.3 These types of long-term exposures to toxic substances leading to disease are expensive to document and, by their nature, chronic exposure results are not available until long after the exposure has begun. Prevention of chronic exposure to these dangerous chemicals is necessary but often more scientifically challenging to demonstrate than for acute exposures.

Regrettable Substitutions
To compound the problem of dealing with the long timeframe to identify and manage chronic chemical exposures is an issue called “regrettable substitution.” An example of this comes from the automotive industry. Car and truck brake pads were traditionally made with an abrasive material including asbestos. As brakes are used, the brake pad material literally turns to dust. This resulted in a health threat to brake maintenance workers who were routinely exposed to brake dust containing asbestos. The automotive industry was encouraged to find a substitute for the asbestos in brake pads to protect workers. In response, manufacturers formulated a brake pad that incorporated a large proportion of copper metal and no asbestos.

As newer copper laden brake pads were used, they deposited copper dust particles along roadways, which were washed into adjacent bodies of water during rain events and dissolved in local waterways. Unfortunately, copper is highly toxic to many aquatic organisms and fish species including trout and salmon. Copper poisoning of aquatic organisms was documented in the San Francisco Bay and the primary source was traced to the normal wearing of the newer copper laden brake pads. The EPA estimated in 2010 that 1.3 million pounds of copper from brake pads was released into California’s environment. The copper was a regrettable substitution for asbestos in brake pads. As a result, California and Washington State have banned asbestos, copper and other selected heavy metals from brake pads.4

 

Figure 1: The Six Classes of Harmful Chemicals. Figure courtesy of Green Science Policy Institute.

 

Agency Environmental Health Protection is Limited
At this point you may be wondering, “Who should be in charge of protecting us all from these toxic chemicals and regrettable substitutions?” A few types of products are approved of for safety, most notably food; coloring additives for food, drugs and cosmetics; medical devices; and drugs by the Food and Drug Administration (FDA). The FDA also has the authority to deem a cosmetic adulterated if it contains poisonous substances that cause injury to the user.5

Most pesticides are regulated by EPA under the Federal Insecticide Fungicide and Rodenticide Act, FIFRA. Federal and state agencies are limited by the scope of authority granted to them by their legislative bodies. These statutory limits often leave gaps in the ability for regulatory agencies to act comprehensively.

A notable regulatory advancement in protecting us from potentially hazardous chemicals is the 2016 Lautenberg Act. This recent act of congress gives the EPA newly expanded authority to use health-based criteria to review chemicals already in commerce as well as develop health-based safety findings for new chemicals before they reach the marketplace.6 A significant new required criteria for evaluating potentially hazardous chemicals is for susceptible subpopulations such as infants, children, pregnant women, workers and the elderly. EPA is working through priority chemicals first, but there are many years of work to do to catch up with the many thousands of chemicals already on the market as well as the 1,000 or so new chemicals proposed to enter the market each year. On December 20, 2019, EPA finalized the designation of 20 chemical substances as a high priority for upcoming risk evaluations.7 At this rate it will be many years before EPA will be able to assure many of the chemicals already on the market are safe and remove the ones proved unsafe.

Good and Bad in the Same Bottle
The same products may be very useful, such as sunscreen, but due to certain chemical formulations pose hazards to humans or the environment. Some sunscreen formulations are thought to be harmful to fish and coral due to endocrine disruption and toxicity.8 This impact to aquatic life is outside of the FDA scope of authority, which is limited to sunscreen (a cosmetic) formulations that harm the user. In this case, the harm is environmental, not to the sunscreen user. Nonetheless, many dive boat operators in Hawaii restrict the sunscreen formulations they allow their customers to use while diving to protect the aquatic flora and fauna, which divers come to Hawaii to experience.

With tens of thousands of chemicals in use in our homes and businesses, how do we make good choices and reduce our exposure to the worst of these potentially harmful chemicals?
Without science-based guidance, we are at the mercy of the commercial marketplace, which promotes a potentially toxic soup in our homes and workplaces in the name of cleanliness, convenience and fresh scent. Fortunately, there are a number of organizations working on these HHW-related issues to help identify and advise us and our customers on the most dangerous chemicals around us and how to avoid the worst of them.

Safer Product Referrals for Your Residents
You and your community can become more aware of safer products and products to avoid from various sources. If your citizens buy less hazardous products, it will mitigate potential harm to them and may eventually reduce the amount of HHW you have to manage. For the general public, a good place to find information about the riskiness of one product versus another is going to the Environmental Working Group (EWG) website where they have science-based evaluations of thousands of products, including cosmetics, sunscreen, pesticides on produce and other consumer-oriented information. This national non-profit is based in the District of Columbia with offices in Minnesota and California. Find their work at www.ewg.org/consumer-guides.

Another non-profit group that has had national influence based on scientific research and policy initiatives is Toxic-Free Future in Seattle, WA. This organization is oriented towards consumer education as well as influencing state and national chemical policy. Their mission is to advocate “for the use of safer products, chemicals and practices through advanced research, advocacy, grassroots organizing and consumer engagement to ensure a healthier tomorrow.” You can leverage their current and past accomplishments athttps://toxicfreefuture.org.

Framing and Advancing Better Chemical Policy
If your HHW job includes a focus on improving chemical policy or regulatory work, there are organizations that are working in this area in addition to the EWG and Toxic-Free Future .
Located in Berkeley, CA, the Green Science Policy Institute develops and communicates peer-reviewed research about chemicals of concern with a focus on translating technical information for use by key decision-makers. This organization educates and partners with and between academia, government, business organizations and other non-profits. This is a high-powered non-profit that is making science real and actionable at the policy and political level. The Green Science Policy Institute has long been involved with endocrine disruptors as well as other classes of dangerous chemicals and problematic products. Find out more about their work at https://greensciencepolicy.org.

The Silent Spring Institute in Newton, MA states in their core value that “everyone has a right to clean air, clean water, and safer products and that no one should get sick from toxic chemicals. Our pioneering approach frames all our research through the lens of ethics, justice, and safety.” As another science-based, consumer protection non-profit, they clearly include women’s health and environmental justice as part of their scientific and policy mission. Unlike some organizations (not mentioned here) that focus on best treatment options or cures after cancer has occurred, the Silent Spring Institute is focused on identification of the chemicals that cause cancer and how we are exposed to those chemicals where we live and work: https://silentspring.org.

Winnowing Down to the Chemicals of Concern and Chemical Classes
To focus the efforts on the most potentially problematic chemicals, a number of organizations have developed categories of products or chemical classes, sometimes referred to as chemicals of concern. In the past, problems with chlorinated or brominated fire retardant materials led to legislation banning one specific chemical from a certain use. Industry responded by using a nearly identical, but technically not that one specific banned chemical, as a direct substitute with the same attendant health risks. Another form of regrettable substitution by focusing restrictions on a single chemical.

At the federal and some state levels, policies and rules are becoming more focused on evaluating and regulating chemical groups or classes that have similar chemistry, functions and
interactions with humans and the environment. The implementation of those broader policies and rules should largely avoid the single-chemical regrettable substitution problem. Groups or classes of chemicals of concern have been developed by the Green Science Policy Institute, California Department of Toxic Substances Control, Washington State Department of Ecology and others.

The Green Science Policy Institute states that “[m]any chemicals of concern can be grouped into just Six Classes, rather than evaluating chemicals one at a time; the class approach allows efficient decision making based on entire groups of chemicals.” Those six classes are shown in Figure 1, page 22.9 At www.Six Classes.org you can view informative four-minute-long videos detailing why the six chemical classes are harmful, where they are used, how to reduce harm and a success story.

The Washington State Department of Ecology developed a strategy to identify priority toxic chemicals using the criteria of Persistence in the environment, whether the chemical Bio-
accumulates in plants or animals, and the Toxicity of the chemical, together shortened to PBT.10 WA Ecology has developed chemical action plans for the following priority chemicals or groups: Per- and poly-fluorinated alkyl substances (PFAS), Polychlorinated biphenyls (PCBs), Polycyclic aromatic hydrocarbons (PAH), Lead, Polybrominated diphenyl ethers (PBDE) and Mercury.

The California Department of Toxic Substances Control (DTSC) used the WA Ecology PBT list, lists from the European Union, and other authoritative California and U.S. agency lists of dangerous chemicals to develop their Safer Consumer Products program.11 Evaluation of these lists formed a priority products list from which DTSC determines if a regulatory response is warranted.12 The DTSC has adopted rules for three classes of priority products and is in the process of considering adoption of eight more priority product groups.

Chemical Classes and Product Design Evolution
This winnowing down from tens of thousands of chemicals in commerce to focus on the most problematic classes of chemicals and product groups will continue. The result should be an evolution of products that are less dangerous to our homeowners, business workplaces and the environment.

Ultimately, the hope is that the makers of the products containing these problematic, potentially harmful chemicals will become sensitized to the need to make safer consumer goods and evaluate likely human health and environmental impacts in the design and formulation of their existing as well as proposed new products. | WA

David Nightingale, CHMM, S.C., is Principal at Special Waste Associates (Olympia, WA), a company that assists communities in developing or improving HHW and VSQG collection infrastructure and operations. They have visited 150 operating HHW collection facilities in North America. As a specialty consulting firm, Special Waste Associates works directly for program sponsors providing independent design review for new or upgrading facilities—from concept through final drawings to create safer, more efficient and cost-effective collection infrastructures. Special Waste Associates also published the book, HHW Collection Facility Design Guide. David can be reached at (360) 491-2190 or e-mail Dave@SpecialWasteAssoc.com.

Notes
Gummin, David D, Mowry, James B, et. al., “Abstract of 2019 Annual Report of the American Association of Poison Control Centers”. National Poison Data System (NPDS): 37th Annual Report – PubMed (nih.gov), December 2020.
2019 Poison Control Data Snapshot, https://piper.filecamp.com/uniq/UbJLy30qeHredpFe.pdf, accessed 6/2/2021.
Multiple Chemical Sensitivity | Johns Hopkins Medicine
Better Brakes Law – Washington State Department of Ecology and Hazardous Materials: Motor Vehicle Brake Friction Materials | Department of Toxic Substances Control (ca.gov)
21 USC 361: Adulterated cosmetics, Title 21-FOOD AND DRUGS CHAPTER 9- FOOD, DRUG, AND COSMETIC ACT SUBCHAPTER VI-COSMETICS
www.edf.org/health/our-updated-chemical-safety-law-lautenberg-act
www.epa.gov/assessing-and-managing-chemicals-under-tsca/prioritizing-existing-chemicals-risk-evaluation
Reef Friendly Sunscreens – Beachapedia
Class Concept – Green Science Policy Institute
Addressing priority toxic chemicals – Washington State Department of Ecology
Authoritative Lists | Department of Toxic Substances Control (ca.gov)
Priority Products | Department of Toxic Substances Control (ca.gov)

References
https://greensciencepolicy.org/our-work/class-concept/
https://ecology.wa.gov/Waste-Toxics/Reducing-toxic-chemicals/Addressing-priority-toxic-chemicals/PFAS
https://ecology.wa.gov/Waste-Toxics/Reducing-toxic-chemicals/Addressing-priority-toxic-chemicals/PCBs
https://ecology.wa.gov/Waste-Toxics/Reducing-toxic-chemicals/Addressing-priority-toxic-chemicals/PAH
https://ecology.wa.gov/Waste-Toxics/Reducing-toxic-chemicals/Addressing-priority-toxic-chemicals/Lead
https://ecology.wa.gov/Waste-Toxics/Reducing-toxic-chemicals/Addressing-priority-toxic-chemicals/PBDE
https://ecology.wa.gov/Waste-Toxics/Reducing-toxic-chemicals/Addressing-priority-toxic-chemicals/Mercury

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