March 5, 2025Sustainable Chemistry Cannot Deliver Environmental Justice Unless Fenceline Communities are Protected

A joint blog by the Environmental Justice Health Alliance for Chemical Policy Reform and Coming Clean.

Blog Post

So-called sustainable and/or green chemistry is being promoted in many circles as a means to both harness chemistry innovation to support more sustainable economies and reduce the environmental and public health impacts of chemical manufacturing. As we work to build research and policy which deliver health protections and justice to communities most impacted by the toxic harm of the chemical industry, we must critically examine sustainable chemistry initiatives and ask who will benefit from the technologies and practices. When something is promoted as “sustainable chemistry,” who is it sustainable for?

While it is groundbreaking to have federal attention and investment in improving the chemical industry, the former administration’s Sustainable Chemistry Initiative failed to deliver Environmental Justice for fenceline communities and risks further entrenching health disparities and toxic contamination in low income and communities of color.

In response to a Congressional mandate, the former White House Office of Science and Technology Policy, established an interagency Sustainable Chemistry Team whose work culminated in two reports. The “Sustainable Chemistry Report: Framing the Federal Landscape”, released August 2023, assesses the current state of sustainable chemistry in the U.S. and defines ‘sustainable chemistry’ for common use. The “Federal Sustainable Chemistry Strategic Plan”, released December 2024, outlines a suggested federal vision and path forward for advancing sustainable chemistry.

Despite naming Environmental Justice and Equity as a “crosscutting theme” in the strategic plan, the substance of the two sustainable chemistry reports do not describe a path towards achieving Environmental Justice for communities most impacted by toxic pollution because:

1) Making chemicals and chemical production safe is not prioritized and communities living with toxic pollution from chemical manufacturing are ignored.

It is widely recognized that communities of color and low-income communities face increased harm from the toxic pollution caused by the production, use and disposal of chemicals. However, reducing this injustice is neither prioritized in the definition of sustainable chemistry nor in the vision for promoting its advancement.

Although reducing the toxicity and release of harmful substances is named as important, and considered an attribute of sustainable chemistry, it is not required for a chemical, or process, to be considered sustainable. Repeatedly throughout both Sustainable Chemistry reports, the drive for sustainable energy, increased efficiency, and alternate feedstocks are mentioned without equivalent mandates for safety and eliminating toxic pollution to fenceline communities.

2) Representatives from EJ and fenceline communities were not included as meaningful and intentional partners/collaborators in developing the definition, vision or plan.

A main principle of Environmental Justice (EJ) is the right to participate as equal partners at every level of decision-making. The report authors acknowledge that any plan related to sustainable chemistry must start with engagement of vested parties. However, it is clear that fenceline and EJ experts from impacted communities were neither considered experts nor parties essential for carrying out this process, and their lived experience was not included in the Team’s outcomes. No fenceline or EJ representatives were invited to participate in the Sustainable Chemistry Team. Similarly, despite holding specific forums for outreach where the expertise of academic and industry representatives were solicited, no forums were held where fenceline or EJ representatives presented their view of what should be considered "sustainable chemistry."

3) False solutions that pose threats to EJ communities and perpetuate injustice are promoted.

The plan focuses on cross-cutting opportunities to develop new technologies, like artificial intelligence (AI) or novel toxicity testing methods, without meaningful discussion of how to ensure that these technologies are verified, can actually deliver health benefits, and include necessary guardrails to protect against harms. Existing gaps in these technologies that perpetuate disproportionate harm are overlooked, particularly when it comes to assessing chemical hazards.

The plan recognizes the need to shift to more renewable sources of energy to power sustainable chemistry efforts, which is also essential for advancing EJ. However, the so-called “clean” alternatives identified, such as hydrogen and nuclear, are a renewed version of “greenwashing” and are recognized by many as “false solutions.” By suggesting these as alternatives, the authors fail to acknowledge the complete supply chain required by these sources, and that EJ communities are disproportionately harmed by resource extraction, fossil fuel pollution and hazardous waste processing and disposal. The current build out of hydrogen is created almost entirely by fossil fuels, and does not prevent health harming pollution in EJ communities, and even more, potentially increases harm. Nuclear energy requires toxic resource extraction for enrichment, which has had a particularly harmful legacy. It also requires long-term waste disposal that must be maintained for generations to come. Given that there is currently no safe path of disposal for existing waste stockpiles, the promotion of additional nuclear reactors, large or small, would only compound the problem.

Similarly, because the plan’s focus on circularity and promotion of recycling, re-use, and a so-called “circular economy” does not require non-toxic and safe chemicals and materials, implementation of the plan could increase toxic pollution in EJ communities. EJ communities already burdened with toxic pollution from battery and plastic recycling facilities are facing new threats from efforts to greenwash plastic waste incineration in the name of a sustainable and circular economy. The strategic plan’s promotion of municipal solid waste and synthetic polymers (aka plastic waste) as sustainable feedstocks for chemical production without guardrails prohibiting toxic pollution, is dangerous for EJ communities.

In the face of renewed attacks on EJ communities and regulatory protections, it is even more critical that efforts aiming to improve chemicals and chemical production not reinforce the racism and injustices of the current chemical system. To achieve that, EJ and fenceline communities must be treated as experts and their representatives, needs, and priorities must be the focus. This also includes rejecting chemistry practices and processes which are documented to further environmental injustices such as:

- - - Technologies which rely on, and support, continued fossil fuel extraction;
    - Using incomplete, and unproven testing methods to conclude that chemicals are safe;
    - Relying exclusively on environmental regulations and permits to protect fenceline communities despite the fact that the current regulatory system continues to allow toxic hotspots in communities of color;
    - Focusing alternative chemistry research on consumer facing products while ignoring the impacts caused by the production of chemical building blocks and intermediates.

If we are to work towards a future that delivers Environmental Justice for communities most impacted by toxic chemical pollution, then we must not settle for programs and initiatives that call themselves “sustainable” or “green” but continue to repeat and “recycle” the same injustices at the fenceline. EJHA and Coming Clean invite partners and allies who are truly interested in advancing Environmental Justice to reject technologies and policies that do not reduce toxic pollution and injustice in EJ communities most impacted by unsustainable chemistry. We must share the sense of urgency that communities and the planet have for "true solutions" - solutions which eliminate the pollution poisoning communities and cooking the planet.