Incorporating Environmental Justice into Alternatives Assessment
Lessons Learned from Case Studies
This report presents new methods for integrating environmental justice (EJ) into chemical alternatives assessment (AA), a key decision-making process used to identify safer substitutes for hazardous chemicals in consumer products. Developed by the Berkeley Center for Green Chemistry (BCGC) in partnership with the California Department of Toxic Substances Control (DTSC) and UMass Lowell, the project aims to ensure that chemical safety evaluations better account for the needs and experiences of disproportionately impacted communities.
Why This Work Matters
Traditional alternatives assessment frameworks often focus on hazard and exposure data without fully capturing the unequal burdens faced by workers, fenceline communities, and other vulnerable populations. This project addresses that gap by embedding EJ considerations directly into the evaluation process—helping regulators and businesses make more equitable and informed decisions about safer products.
What We Did
BCGC applied and tested EJ-informed methods through two case studies:
- Triphenyl phosphate (TPhP) in nail products, focusing on nail salon workers as a priority population
- PFAS in floor polishes and waxes, examining impacts across the full product life cycle
Across both studies, the team:
- Integrated community engagement and worker perspectives into hazard assessment
- Identified priority health endpoints based on real-world exposures and lived experience
- Applied life cycle thinking to capture impacts from production through disposal
- Evaluated existing EJ screening and assessment tools
- Developed and tested methods for weighting health impacts based on population relevance
Key Findings
- EJ can be meaningfully incorporated into alternatives assessment using practical, adaptable methods.
- Community-informed priorities (e.g., respiratory and skin impacts for workers) can be systematically integrated into hazard scoring.
- Life cycle approaches reveal hidden impacts, particularly for upstream communities and workers.
- Weighting health endpoints based on EJ considerations changes how alternatives are evaluated, even if it does not always change final rankings.
- There are still data gaps, methodological challenges, and implementation barriers that must be addressed to fully operationalize EJ in AA.
Impact and Recommendations
The report provides actionable recommendations for improving DTSC’s Safer Consumer Products (SCP) Alternatives Analysis process, including:
- Expanding guidance on community engagement and data collection
- Enhancing tools to evaluate disproportionate exposures and cumulative impacts
- Supporting businesses in developing core competencies in EJ-informed decision-making
Ultimately, this work helps shift alternatives assessment from a purely technical exercise to one that centers equity, lived experience, and real-world exposure, advancing safer products and more just outcomes.