Environmental Health Perspectives Supplements101 (Suppl. 2): 221-225 (1993)

Protecting Reproductive Health and theEnvironment: Toxics Use Reductionby Kenneth Geiser

Toxics use reduction is a new chemical hazard management approach that has emerged in several state lawsover the past years. While toxics use reduction has been promoted as a means of preventing environmentalpollution, little thought has been given to its adoption as a means of managing reproductive hazards. Thispaper provides illustrations of use reduction approaches to conventionally recognized reproductive anddevelopmental toxicants. These approaches will require the opening of a new dialogue between industrialdesigners and process managers and those most concerned about reproductive health. Several differentstrategies are proposed that might be adopted into state programs for promoting reduction in the use ofreproductive and developmental toxicants.

IntroductionToxics use reduction is a new approach to managing

industrial toxic chemical exposure that stresses reducingthe use of toxic chemicals or the generation of toxic wastes.In contrast to conventional approaches to toxic chemicalmanagement that have emphasized engineering controlsand personal protective equipment for protecting workersand end-of-pipe pollution controls for safeguarding theenvironment, toxics use reduction focuses on changes inthe chemical inputs, product outputs, and manufacturingprocesses of industrial production. This new approach hasbeen adopted in several states and written into severalpending bills before Congress. To date there has been no

formal or systematic effort to link ongoing work in toxicsuse reduction with reproductive hazards. The objective ofthis paper is to consider some ofthe opportunities inherentin such a confluence.

What is Toxics Use Reduction?Toxics use reduction is a fundamental form of pollution

prevention. The concept of pollution prevention first devel-oped as a means of reducing the rising flood of hazardouswastes flowing from industrial production facilities. By themid-1980s, it had become clear that the conventionalapproaches to managing industrial wastes by permittingand standard-setting simply were not sufficient (1).

Toxics Use Reduction Institute, University of Massachusetts Lowell, 1University Avenue, Lowell, MA 01854

This manuscript was presented at the Workshop on Occupational andEnvironmental Reproductive Hazards that was held 20-22 November1991 in Woodshole, Massachusetts.

The policy of regulating the release of environmentalpollutants had been built on assumptions that smallamounts of toxic substances could be safely assimilatedinto the environment and that effective government actioncould focus on controlling, rather than eliminating, therelease of these pollutants. Throughout the decade, indus-try invested millions of dollars in pollution control technol-ogies, and Federal and state governments processedhundreds of thousands of pollution release permits. Yet,despite all of this environmental regulation, the volume oftoxic and hazardous wastes has continued to increase, andthe indicators of environmental quality have shown littledramatic improvement. With industry facing rising wastemanagement costs, communities resisting the siting ofwaste management facilities, and environmentalists frus-trated with poor results, the context was set for rethinkingthe future of the environmental regulatory system.The new approach, often called pollution prevention,

shifted policy attention from the control of wastes at theend of the discharge pipe to prevention ofthe generation ofwastes at earlier steps in the production processes (2).Toxics use reduction developed as a specific response to theindustrial use of toxic chemicals. The idea of toxics usereduction is to change the technologies or materials usedin industrial production to reduce the hazards of the wastestream.The concept of toxics use reduction was first integrated

into state law in 1989 when both Massachusetts andOregon passed similar laws. Once these first state lawshad been adopted, it became apparent that programsdesigned to reduce the use of toxic chemicals in industrialfacilities could generate many benefits in addition to thereduction of environmental contaminants. Toxics usereduction offered an opportunity to promote both occupa-

K GEISER

tional and environmental health in the same undertaking.Chemical risks to workers could be reduced, communityhealth risks from chemical storage and transport could belessened, and firms could decrease the compliance, lia-bility, waste management, and purchase costs associatedwith the use of toxic chemicals (3).

Toxics use reduction programs typically require indus-trial plant staff to inventory and analyze the use of toxicchemicals in their facilities and to identify ways to reduceor eliminate them. The programs often require the devel-opment of special "facility plans" that identify a short listof targeted toxic chemicals, set goals for reduction in theuse of those chemicals, and then present selected technicaloptions for implementation. The technical options includechemical substitutions, production process changes, prod-uct redesign, improvements in operations and mainte-nance, and in-process recycling and reuse (4).By 1990, nine states had passed pollution prevention

legislation with at least some toxics use reduction compo-nents (5). Table 1 identifies the states that passed pollutionprevention legislation before 1991, as well as three addi-tional states that passed similar legislation during 1991.These state programs often designate the Federal

Toxics Release Inventory list of Extremely HazardousChemicals (Section 313) as the defining list of toxic chemi-cals (6). Typically the laws include a statewide goal forachieving reductions in hazardous waste generation andstate encouragement or mandates to promote facilityplans. While these plans are often proprietary, most stateprograms require some public data reporting in order tomeasure the progress of firms implementing the pro-grams. Free state technical assistance is frequentlyoffered to assist those firms less technically capable.

The Potentials of Toxics UseReduction

Toxics use reduction represents a policy approachthat is conceptually distinct from and discontinuous withthe conventional environmental regulatory policies thathave dominated state and Federal government action overthe past two decades. Toxics use reduction does not rendersuch regulations obsolete; indeed, this approach flourisheswhere regulations are tight. However, toxics use reductiondoes offer an opportunity to bypass some of the problemsof conventional regulations, such as the slow chemical-by-chemical momentum, the highly contentious threshold-setting process, the costs and imperfections of risk assess-ments, the endless problems of enforcing compliance, andthe constant threat of litigation and delay.

Table 1. States with toxic use reduction or pollution preventionlaws, by year of passage.

1989 1990 1991Illinois Georgia ArizonaMassachusetts Indiana New JerseyOregon Maine Vermont

MinnesotaTennesseeWashington

Toxics use reduction does not become an attractiveapproach if it is seen as simply an extension of the regula-tory approach. In order to envision the possibilities inher-ent in toxics use reduction, it is necessary to break with theregulatory paradigm and reconsider the focus of policyand the operating relationships among government, indus-try, science, labor, and community. Working with firms toencourage innovation in materials and technologies inorder to reduce risks offers a new role for state agents.Advising policy makers on priority chemicals for usereduction and exploring new ways of thinking about the"safeness" of potential toxic chemical substitutes offer newroles for scientists and risk assessors. Searching for new"safer materials" and "cleaner technologies" providesinnovative missions for engineers and university researchcenters. Negotiating with management about chemicalsubstitutions and production transitions offers new oppor-tunities for unions to advance health and safety whileprotecting jobs. Educating the public about the health andenvironmental risks of consumer products and the pro-cesses necessary to manufacture them leads to a moredemanding public better able to make wise collective orindividual choices about the chemicals in its midst.

This search for a new policy perspective is emerging aswe come to understand that no matter how much money,science, or enforcement power we dedicate to the regula-tory approach alone, the costs and the problems associatedwith the use of toxic chemicals will continue to outstrip ourcapacity to achieve a safe and clean workplace and environ-ment. Although toxics use reduction programs have beenmoving forward among the states, little has been done toconsider the implications for the reduction of reproductivehazards.

Toxics Use Reduction as a Responseto Reproductive Hazards

Toxics use reduction focuses on chemical hazards. Phys-ical hazards such as ergonomic stressors or radiation arenot covered by toxics use reduction. Toxics use reduction ismost appropriately applied to reproductive or developmen-tal hazards (chemicals or biologicals) used in industrial orcommercial settings. From a process design perspective,reproductive and developmental toxicants are little differ-ent from any other toxic chemical. The techniques thatcommonly characterize toxics use reduction can as likelybe applied to reproductive hazards as to any other tar-geted industrial substance. Therefore, the policy task is toidentify specific reproductive and developmental toxicantsand assess the opportunities for substitution or replace-ment by changes in material inputs, production processes,or product design.

Table 2 lists some commonly recognized reproductive ordevelopmental toxicants (7) along with examples of sub-stitutes or changes in use that reduce exposure. Theseexamples are offered primarily for illustration. There aremany other options. A serious toxics use reduction pro-gram focused on reproductive hazards would require moredetailed analysis tailored to specific industrial uses. How-ever, it is encouraging to note the opportunities to reduce

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Table 2. Use reduction illustrations for common reproductive ordevelopmental toxicants.

Lead Much has already been done in the United States tophase out lead in gasoline and paint. Lead waterpipes can be replaced with copper tubing. Lead-based paints have been replaced for most domesticuses. Lead is still extensively used in lead-acid auto-mobile batteries. Researchers working on the solar-powered car claim that there are alternatives to leadin electric storage batteries, but the price would behigher.

Mercury Mercury is now being replaced as a bactericide inpaints. Some European countries are leading theway in phasing out mercury in dry cell batteries.

Organic solvents The state toxics use reduction programs are findingthat chlorinated solvents can be relatively easilyreplaced in many industrial cleaning and degreasingoperations by alkaline or aqueous-based cleaners orby simply eliminating unnecessary cleaning anddegreasing steps. A British firm is marketing analternative dry cleaning process that would sub-stitute a dry vacuum operation for perchloro-ethylene in clothes cleaning.

Ethylene oxide Ethylene oxide can be replaced with super-heatedwater, hydrogen peroxide, or ozone-based processesin hospital sterilization. Ethylene oxide used in anti-freeze formulations can be replaced with alcohols.There are a host of alternative fumigants availablefor ethylene oxide used in food processing.

Pesticides DDT was phased out of use in the United States in1972. Chlordane and heptachlor have both beenreplaced by other pesticides following the 1976Federal restrictive use ruling. Although Federalregulations still permit the use of chlordane as atermaticide, termites can be controlled throughcareful architectural controls. Kepone has been fullyreplaced with various integrated pest managementpractices. Many reports, including those of theNational Academy of Science, show that nonchemi-cal alternatives to the use of pesticides in farmingneed not reduce crop yields or farm income.

Polychlorinated Polychlorinated biphenyls have been phased out ofbiphenyls all but contained electrical equipment in the United

States.

Glycol ethers The ethylene glycol ethers (monoethyl and mono-methyl) are used extensively in the semiconductorindustry where, in some uses, they can be replacedwith propylene-based products. There are manymastics and organic resins that can be used toreplace epoxy resins that contain glycol ethers.Glycol ether based de-icing can be accomplishedwith electric heaters, proper winter cover, or highpressure pellet blasting.

the use of some of the most common reproductive anddevelopmental toxicants.

Integrating Reproductive Hazards intoToxics Use Reduction

If toxics use reduction programs are to addressreproductive hazards, there will need to be some shift in

attention among those who know the most about thereproductive effects of toxic chemicals. Epidemiologists,toxicologists, clinicians, health educators, and environmen-tal and occupational health advocates often know littleabout the processes of industrial production, includingwhere and how specific chemicals are used, why they areused, and what alternatives exist. On the other hand,industrial designers, process engineers, and productionmanagers who specify industrial chemical use have littleopportunity for dialogue with those who know aboutreproductive and developmental toxicants. The first initia-tive in making toxics use reduction relevant to reproduc-tive hazards will require the bridging of this broadintellectual and disciplinary gap.

Experts who know about reproductive hazards will needto go beyond the conventional exposure control thinkingthat for years has terminated their policy and patient careresponsibilities (8). Pollution prevention and toxics usereduction have extended the traditional focus of environ-mental professionals into the design and management ofindustrial processes. Reproductive health advocates needto broaden their focus as well. They need to learn moreabout manufacturing and open new avenues to teach thosewho design and run manufacturing processes aboutreproductive and developmental toxicants. Within thisexpanded dialogue, toxics use reduction can become arelevant means to promote reproductive health.

Given this expanded dialogue, there are several initia-tives that could address reproductive hazards throughtoxics use reduction, as explained below.

Inclusion of Reproductive and Developmental Toxi-cants on Toxics Release and Toxics Use Databases.Toxic use reduction programs typically rely on specifiedlists of substances as a means of defining "toxic chemi-cals." Many of the state toxics use reduction programs usethe Federal Extremely Hazardous Chemicals list found inSection 313 of the Federal Emergency Planning and Com-munity Right to Know Act of1986 (EPCRA) as the criterialist for defining the chemicals targeted for use reduction.Much of industry's attention has turned to this same listdue to the annual Toxics Release Inventory (TRI) man-dated under EPCRA. The TRI is a compilation of toxicchemical release reports from over 60,000 industrial facili-ties throughout the country. The Extremely HazardousChemicals list has been developed from two state lists thatwere drawn from literature based on various risk assess-ment studies. The list has not been adequately consideredin terms of reproductive or developmental toxicants, andmany toxicants known to affect reproductive health maybe excluded from the list. Each year the list is adjusted asnew information is accumulated. The EPCRA law permitsmembers of the public to petition for the addition ofchemicals to the list. Reproductive health advocates couldcall for an analysis of the list in terms of inclusion of allknown reproductive and developmental toxicants.Reproductive and Developmental Toxicants as Pri-

ority Targets for Toxics Use Reduction Programs. Sev-eral states now have toxics use reduction programs thatare advanced enough to be considering priority settingamong chemicals on the lists. Consideration of reproduc-

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tive hazards at this time could help to focus state programseither on high-priority reproductive and developmentaltoxicants or on industries in which these hazards arecommon. The first approach (the chemical approach) couldencourage all targeted firms to give primacy to the reduc-tion of reproductive and developmental toxicants. Thesecond approach (the industries approach) could guidestates to give highest priority for technical assistance andperformance evaluation to those industries in whichreproductive hazards are most common. States could beencouraged to include reproductive and developmentaltoxicants among their highest priorities and require spe-cific reduction data from firms that currently use targetedreproductive and developmental toxicants.Exclusion of Reproductive Hazards as Substitutes

for Targeted Toxics Use Reduction. One common methodof toxics use reduction involves the substitution of onechemical for another. Most state programs give littleguidance on those substances that are to be consideredacceptable substitutes. In order to assist in this area, someadvocates have suggested a "safe substitutes" addendumto state laws or the development of a practice protocolcalled "substitution analysis" that would guide thoseimplementing toxics use reduction programs in movingtoward safer substitutes. The exclusion of reproductivehazards as acceptable substitutes for toxic chemicals tar-geted for use reduction could be included as a basic tenet ofany proposed safe substitutes policy. Similarly, the perfor-mance of a substitution analysis to assess options fortoxics use reduction could include a requirement to evalu-ate the reproductive and developmental effects of anyoption proposed.Reproductive and Developmental Toxicants as Pri-

orities for "Chemical Sunset" Policies. Increasingattention is now turning to the use of chemical bans andphase-out policies as adjuncts to toxics use reduction. TheSwedish Chemicals Inspectorate has proposed to theinternational Organisation for Economic Cooperation andDevelopment (OECD) a "chemical sunsets" policy thatwould commit OECD countries to phased reduction inproduction and use of a consensus list of highly toxicchemicals (9). Some ofthe substances in the initial Swedishproposal are known reproductive hazards (e.g., lead). Inselecting chemicals for bans or sunsets, reproductive anddevelopmental effects could be raised as high-rankingcriteria.

Alternatively, a call could be initiated for a national orinternational phase-out of the use (or production) of spe-cific well-recognized reproductive and developmental toxi-cants. Although the consequences of such a phase-outwould require much more investigation, the call itselfmight serve to raise the current level of public and techni-cal discussion.

Toxics Use Reduction as a Response to Plant ClosureThreats at Sites Where Reproductive Hazards HaveBecome an Organizing Issue. Firms confronted withworker or community demands to remove reproductivehazards may respond with threats to close operations.Such threats, or the anticipation of such threats, candampen the strength of local level advocacy. Demands for

toxics use reduction programs offer a positive and lessthreatening option that may allow workers or citizens topress for reproductive hazard elimination in a manner thatis acceptable to facility managers. The programs in placearound the country can be used as models for constructiveadvocacy. The identification of similar facilities that havesuccessfully reduced toxic chemical use through such pro-grams may provide an inducement to reluctant managers.Compensation Programs That Protect Workers Dis-

placed by Reproductive Hazard Elimination Programs.In some cases, the reduction or elimination of specificreproductive hazards from industrial users may result inextreme dislocations for workers who have mined, man-ufactured, or synthesized those substances. Phasing outlead, for instance, would result in the closing ofthe last twocommercial lead mines in the United States, as well as theclosing of several lead smelters. The burden of thesedislocations should not be thrust upon workers and com-munities without economic assistance. A special govern-ment fund, perhaps generated by a special fee on chemicalproducers, should be established to provide the resourcesnecessary for making these transitions in a manner that isfair and equitable (10).

Who Needs to Do What?Conventional thinking about reproductive hazards is

still dominated by a regulatory mind set. Most of the policywork is consumed in determining safe levels of exposure torecognized reproductive hazards or the removal of vulner-able populations from such exposures (11). For the nearterm, standard setting remains an important policyinstrument. However, a more fundamental preventiveapproach requires that increasing attention be turned tothe reduction and elimination ofuse ofknown reproductiveand developmental toxicants. This goal will require a shiftin focus and action for those most concerned aboutreproductive hazards.

Environmental organizations that currently advocatetoxics use reduction policies need to become more familiarwith reproductive and developmental toxicants and theirhealth risks. Human reproductive health, particularly thatof workers, needs to be considered as important an endpoint as human cancer reduction, atmosphere protection,or ecological integrity.The idea of reduction in use of reproductive and develop-

mental toxicants needs to be more forcefully embraced bynational reproductive health advocacy organizations. Tar-geted chemical elimination in industry and commerceneeds to become a more central tenet of male and femalereproductive health promotion.

Business organizations must become better educatedabout the costs of using reproductive or developmentaltoxicants in industrial production. Firms that have suc-cessfully reduced or eliminated known reproductive haz-ards need to be publicized and studied for the lessons thatthey present. Trade unions must become more assertive innegotiating for the removal of highly toxic chemicals,including reproductive hazards, from production opera-tions where they seek to protect jobs and upgrade the

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conditions of the work environment. Governments at alllevels must become more aggressive in targeting certainhighly toxic chemicals such as reproductive and develop-mental toxicants and working with industry to affect thereduction and elimination of these substances.

Toxics use reduction is an action-oriented approach tothe safe management ofindustrial chemicals. Where it hasbeen implemented, toxics use reduction has encouragedcreative new techniques for the manufacture ofproducts inways that are less hazardous to workers and consumersand more compatible with the environment. Our approachto reproductive hazards should be similarly focused ondesigning industrial production processes that minimizethe threat to reproductive health. Although the futurerequires more research and better controls on reproduc-tive and developmental toxicants, we need to begin now topromote policies that encourage the design of cleaner andsafer production systems that function without reproduc-tive concerns.

This paper was initially drafted with the assistance ofBeverly Johnsonand Lin Nelson, who also helped to facilitate the conference workinggroup that considered this paper. Pat Costner, Libby Averill, TheoColburn, Barbara Chapman, Arthur Bloom, and Jim Donald participatedin the working group and offered valuable advice and comments. All ofthese contributions are acknowledged and appreciated.

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