Can There Ever Be Such a Thing as a Sustainable Chemical Standard?

The American Chemical Society Green Chemistry Institute® (ACS GCI) has teamed with stakeholders from industry, non-governmental organizations, and Federal and State agencies to develop a Sustainable Chemical and Process Technology Standard for the chemical industry.  As stated in the January 2009 memo from the ACS GCI, the new Standard is intended toâ¦

â¦establish consistent requirements for sustainable chemical products and production technologyâ¦to demonstrate how chemical products can conform to the environmental, economic, and social principles of sustainability throughout the supply chain; and to encourage participation by all chemical manufacturers to maximize impact reductions and enhance environmental accomplishments.

Itâs curious how this Standard will integrate with existing environmental regulations at chemical production facilities.  For example, Shell Chemical Yabucoa, a petrochemical facility in Puerto Rico, has received a compliance order from the USEPA.  The facility has a permit to discharge treated wastewaters, yet it violated the permit by discharging to the wrong location, a.k.a., leaking pollutants, twice so far in 2009.  We are hopeful that the Shell Chemical personnel at this facility are making efforts to reduce impacts to the environment, yet they seem to be having a hard time with this persistent leak.

Will the Sustainable Chemical and Process Technology Standard capture how the facility responds to the leak, the turnaround time to repair the leak, the adverse environmental health consequences of the leak, or the compliance penalties assessed by Federal agencies?  Letâs hope that the new Standard will be able to identify and assess chemical production footprint fluctuations all along the supply chain.

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You're posing a worthwhile question. My gut sense says "no" with today's regulatory climate, though I'll acknowledge that my assertion warrants some follow up. However, I'll pose a couple of examples: RCRA requirements for hazardous waste identification, treatment and disposal; NESHAP standards for toxic air pollutants and TSCA testing requirements all may be too hard-wired to allow the flexibility and innovation that green chemistry approaches will demand. The regulatory framework, relationships between regulators and regulated community, and the standard of care exerted by the regulated community, all have to be in a radically different place than where they are today, for a sustainable chemical standard to work.