Principles and tools of chemical regulation: a comment on 'the substitution principle in chemical regulation: a constructive critique'

In this short comment, we make three points. First, replacing one chemical with another should be seen as only one of a portfolio of tools to manage the risks of existing chemicals. Substitution is preferable when it offers attractive benefits (relative to costs and risks) compared to the next-best alternative measure. Depending on the nature of the market failure and the cost-effectiveness of alternative measures, chemical replacement may or may not be the preferred remedy. Second, the principle of substitution, like its close cousin precaution, is a guideline for consideration by decision-makers rather than a policy tool. Confusion can arise when the principle of substitution is treated as if it is an operational tool. Finally, the most difficult challenge in chemicals risk management is how to create proper incentives for continuous safety improvements through a variety of risk management measures, including substitution. Chemicals already on the market have a commercial advantage over chemical innovations that may be safer, greener and otherwise preferable. We offer some general comments about how the incentives faced by industry can be modified to accelerate risk management, including advances in green chemistry.