OSTP requests information on sustainable chemistry

The Office of Science and Technology Policy (OSTP) issued on April 4, 2022, an Interested Party Request for Information (RFI) on federal programs and activities supporting sustainable chemistry. 87 Fed. Reg. 19539. The OSTP notes that “[t]The term “sustainable chemistry” has no consensus definition and most uses of the term indicate that it is synonymous with “green chemistry”. The OSTP requests information on the preferred definition of sustainable chemistry. The OSTP is also seeking input on how the definition of sustainable chemistry might impact the role of technology, federal policies that may help or hinder sustainable chemistry initiatives, future research to make advancing sustainable chemistry, financial and economic considerations, and federal agency efforts. The OSTP states that it will use the comments provided in response to the RFI to address National Defense Authorization Act (NDAA) Title II Subtitle E (Subtitle E), which includes the text of the bipartisan Sustainable Chemistry Research and Development Act of 2019. Subtitle E directs the OSTP “to identify research questions and priorities to promote transformational progress in improving the sustainability of chemical sciences”. Comments are due by 5:00 p.m. (EDT) June 3, 2022.

As noted in our January 19, 2021 memo, Subtitle E directed the OSTP to create a consensus definition of the term “sustainable chemistry” to coordinate federal programs and activities in support of sustainable chemistry. According to the OSTP, the definition will inform its development of a framework of attributes characterizing sustainable chemistry, as well as quantitative assessment measures. Additionally, it will allow the OSTP to assess the state of sustainable chemistry in the United States; coordinate and support federal research, development, demonstration, technology transfer, commercialization, education, and support for public-private partnerships; identify federal obstacles and opportunities; identify scientific challenges; avoid duplication; and positioning federal funding for maximum impact, including through synergistic partnerships.

The OSTP invites input from all interested stakeholders, including industry and industry association groups; civil society and advocacy groups; local organizers and community groups; state, local and tribal governments; university researchers; technical practitioners specializing in chemistry and chemical processes; and members of the public representing all walks of life and perspectives. The OSTP states that it “has a great interest in receiving contributions from parties developing sustainable chemical technologies, parties acquiring and using these technologies, and people from communities affected by their use, including, but not limited to limit, environmental justice communities”.

According to the notice, the OSTP considered definitions of sustainable chemistry to potentially include the integration of technology, politics, finance/economics, energy, national security, critical industries and critical natural resources. The OSTP encourages contributions on these and other considerations for a definition of sustainable chemistry. The OSTP suggests respondents provide information on the following topics:

  • Definition of sustainable chemistry: The OSTP is mandated by Subtitle E to develop a consensus definition of sustainable chemistry. The OSTP is asking for comments on what this definition should include. The definition will inform the OSTP and federal agencies to prioritize and implement research and development (R&D) programs to advance the practice of sustainable chemistry in the United States. The OSTP also invites comments on how the definition of “sustainable chemistry” relates to the common use of “green chemistry” and whether these terms should be synonymous, exclusive, complementary, or whether one should be incorporated into the other.
  • Technologies that would benefit from federal government attention to move society toward more sustainable chemistry: Which technologies/sectors will benefit the most from advances in sustainable chemistry or which require priority investment? Why? Which mature technology areas, if any, should be given lower priority?
  • Basic research areas: Which basic and emerging research areas require increased attention, investment and/or priority to support innovation towards sustainable chemistry (for example, catalysis, separations, toxicity, biodegradation, thermodynamics, kinetics, life cycle analysis, market forces, public awareness, tax credits). Which federal research area would you consider mature and/or solidly covered, or which federal programs would benefit from increased prioritization?
  • Outcome and potential outcome measures based on the definition of sustainable chemistry: What results and output measures will allow the OSTP to prioritize initiatives and measure their success? How to determine the effectiveness of the definition of sustainable chemistry? What are the characteristic quantitative features of sustainable chemistry?
  • Financial and Economic Considerations for Advancing Sustainable Chemistry: How are financial and economic factors taken into account (for examplecompetitiveness, outsourced costs), evaluated (for examplebusiness models, full life cycle management tools), and implemented (for exampleeconomic infrastructure)?
  • Policy considerations for advancing sustainable chemistry: What policy changes could the federal government make to improve and/or promote sustainable chemistry?
  • Investment Considerations When Prioritizing Which Federal Initiatives to Consider: What issues, consequences and priorities are not necessarily covered by the definition of sustainable chemistry, but should be considered when investing in initiatives? Subheading E includes the phrase: “support viable long-term solutions to a significant number of challenges”. The OSTP says it expects the final definition of sustainable chemistry to take strong account of resource conservation and other environmentally focused issues. For example, according to the OSTP, national security, jobs, funding models, partnership models, critical industries, and environmental justice considerations can all lead to consequences of implementing sustainable chemistry initiatives. such as the dematerialization or the reduction of the quantities of materials necessary to serve an economic function.

Remark

The OSTP Information Request does a good job of addressing the issues that NDAA Subtitle E requires the OSTP to address, the most important of which is the creation of a consensus definition of the term “sustainable chemistry”. “. Sustainable chemistry, however defined, should be at the center of federal R&D efforts as the country develops innovations to enable a more sustainable future – a future less dependent on extractive resources; one with a lower carbon footprint; one that manufactures, processes and uses less hazardous substances; and one that is more circular. Defining sustainable chemistry is a key first step, and readers are encouraged to engage with the OSTP to ensure that various government agencies are well aware of the scientific and business realities of developing more sustainable chemical technologies. As the notice clarifies, the OSTP seeks information far beyond what is needed for definition. For example, the OSTP specifically seeks information on “policy considerations for advancing sustainable chemistry”. Specifically, the OSTP seeks information on “[w]What policy changes could the federal government make to improve and/or promote sustainable chemistry? For those of us deeply concerned about the state of the review of new chemicals under the Toxic Substances Control Act (TSCA), this initiative provides a critically important forum to educate and advocate. .

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