The Birth of Green Chemistry: A Political History

Introduction

On their website, the US Environmental Protection Agency (EPA) defines green chemistry (GC) as “the design of chemical products and processes that reduce or eliminate the generation of hazardous substances.” Since being promoted in the 1990s in the United States, the term has been increasingly used in academic literature (Linthorst 2010) as well as in communication by the industry, particularly as “sustainable chemistry.” However, the meaning of the term remains debated and unclear, with varied meanings according to the context (Maxim 2018). Several scholars have analyzed the factors that prevent wider adoption of GC (Matus et al. 2007; Matus et al. 2012; Iles 2011), while others have used bibliometric methods to evaluate its diffusion in scientific literature (Linthorst 2010). Nonetheless, very few authors have looked into where the idea of greening chemistry originally came from.

A widely cited attempt to theorize the emergence of GC is Woodhouse and Breyman’s (2005) paper, which offers an analysis from the perspective of social movement theory. These authors asked whether GC, an “environmentally responsible technological innovation,” was in fact “led by technoscientists working within mainstream corporate, governmental and university institutions” (p. 199). They explored the possibility that GC could be a social movement, that is, “organized networks whose members work within political opportunity structures while sharing identifiable discourses, ideologies and strategies” (p. 200), originating in the efforts of a small group of technosphere insiders. The networks of researchers and administrators created around the GC terminology might form an “elite movement” (p. 209), that is, a small-scale social movement of highly trained experts. The hypothesis of a social movement as driver for GC was further rediscussed in the literature: Roberts (2005) analyzed the progressive discursive construction of the term and expressed doubts about its “scientific” nature. More recently, Murphy (2020) focused on whether GC really was a novel creation of the US EPA, showing that GC terminology evolved from pollution prevention (PP) approaches, which existed long before the 1990s and originated in the industry. Addressing the question of whether GC is truly an environmentally responsible innovation, I (2018) previously argued that—beyond a small minority of committed individuals—the wider community of chemists can pair or replace ethical commitments with pragmatic considerations in. Many chemists use the term “green chemistry” flexibly to suit the context and their audience. Their choice to use the term or not, and the content to which they associate it, is heavily influenced by the specific context of research policies and environmental policies in which they work.

This paper began as an investigation of whether committed individuals were able to divert institutional and financial resources to support their ethical engagements. I argue here that the emergence of GC does not reflect only the success of individuals who took advantage of existing political resources but is rather an expression of major political changes in the management of chemical risks. GC is a tool (among others) for managing chemical risks at the EPA in the 1990s. Thirty years after the originating events of GC—a time lapse that allows a long perspective on the historical evolution of the concept—the findings of this paper complement the existing literature with an analysis of the political drivers of GC, which relates the action of enthusiastic hard-working individuals to the regulatory politics and political aims prevailing at the EPA’s chemicals program in the late 1980s and 1990s.

Indeed, the 1990s mark a shift in the framing of chemical risk policies at the agency. EPA policies had gradually changed from the precautionary regulatory stance of the 1970s. A marked change occurred after a key 1991 asbestos lawsuit that confirmed the EPA’s inability to ban toxic chemicals under the Toxic Substances Control Act (TSCA). The asbestos case arrived at a time when the agency had been under criticism for years for its “command and control” pollution management policies (US Congress, Congressional Budget Office 1985; US Congress, Office of Technology Assessment 1986). As a consequence, the EPA then directed its efforts toward establishing a cooperative approach with the industry, by promoting technical, financial, and political support for its voluntary measures. One of the hallmarks of this political transition is the emergence of GC as a strategy for chemical risk management, which in light of a regulatory “comanagement” approach (Maxim and Berger 2020) can be described as a “design” produced by the EPA in response to ongoing controversies to restore its own legitimacy (Demortain 2020).

Background

Around the time of its creation in 1970, its first Administrator described the EPA as “an independent agency. It has no obligation to promote agriculture or commerce; only the critical obligation to protect and enhance the environment” (Ruckelshaus 1970). Born out of concerns about chemical pollution, EPA has been in charge of implementing numerous legislative texts that aim to measure and control toxic chemicals in the air, water, soil, food, and consummer products.

To analyze the nested history of the EPA’s institutional organization and use of risk assessment, Demortain (2020, 23) proposed the notion of design—defined as “an iterative process of formal, purposive assembling of an organization to counter controversies and enhance its credibility as a producer of legitimate outcomes.” Design aims to legitimate administrations confronted with crisis and forms a screen that structures their interactions with their audiences in controllable ways. It is an iterative process set in motion by successive controversies. For the EPA, design refers to the agency’s reconfiguring of its organizational structure (offices, work programs) and human/financial resources in parallel with a renewal of its conceptual resources (Demortain 2020)—by adopting terms such as risk assessment, risk management, or GC.

Scientization is an essential component of design that makes it possible to restructure problems and formulate solutions that respond to controversies while benefiting from the reputation of neutrality and the legitimacy of science. In this paper, scientization refers to a form of institutional communication about a concept (here, GC) which discursively presents the concept as resulting solely from a scientific process aiming to produce objective, apolitical knowledge. While that concept does have roots in academic work, it is nevertheless (re-)defined in practice in a way that serves specific political purposes. This notion is particularly suitable when analyzing the creation of GC in the context of the 1990s: at this time, the EPA was being confronted with criticism of its chemicals policy from all sides. Furthermore, Republican administrations at the time were supporting a deregulatory context. Design is much influenced by people with backgrounds in scientific disciplines, working at the science–policy interface—as was the case for Paul Anastas at the EPA at the time. It depends on their particular competences, which can heavily influence the meaning that is given to a concept.

Demortain identifies two main activities that shape design. The first is the “creation of knowledge representation,” that is, common objects of attention (GC) and the forms of knowledge necessary to know this object (scientific knowledge). The second is the delimitation of organizational roles and identities to reinvent the agency’s mode of functioning and produce legitimate outcomes—which involves creating networks of people who carry that knowledge and articulate their work through specific rules.

The interest of looking at design networks is also suggested by the literature describing ethical engagements in engineering. Thus, Conlon and Zandvoort (2010) show that the “individualistic approach”—which assumes that the adoption of an ethical orientation in engineers’ work is essentially dependent upon these individuals having learned the relevant concepts and theories—does not account for the broader context of their activity and is therefore counterproductive. They argue that engineers cannot easily solve ethical dilemmas at an individual level and depend instead on structural social, legal, and political factors, which can only be modified by policy changes. The economic system and associated corporate environment keep engineers “captive,” ultimately making them unable to take individual initiative to prioritize public health (Conlon 2019; Swierstra and Jelsma 2006; Lynch 2015).

In methodological terms, all these results encourage an analysis of the origins of GC in the context of environmental policies at that time. This paper uses Demortain’s theorization of design to do so. I focus on the first design step, namely why and how the meaning of GC was drafted to serve the comanagement policy at EPA in the 1990s, and how its affiliation with science was engineered. The second step of the sequence—the creation of institutional and organizational structures to promote GC—was extensively addressed by Woodhouse and Breyman (2005).

In addition to the core methodological approach of design, a useful theoretical resource for describing the chemical regulatory model is the comanagement framework proposed by Maxim and Berger (2020). Comanagement is a political strategy where regulators seek to reach compromise and pedagogically shape the chemical industry’s behavior instead of constraining and sanctioning it.

The comanagement regime has the following characteristics:

A pronounced asymmetry of both information and material resources between the regulator and the regulated, benefiting the latter.

While applied initially in the context of European chemical regulations, the comanagement framework also proves helpful, albeit not fully applicable, for analyzing US chemical policies.

Woodhouse and Breyman (2005) asked if individuals with ethical motivations and access to institutional resources have been able to drive environmentally responsible innovation in the field of chemicals. Indeed, the director of the GC program within the Office of Pollution Prevention and Toxics at the EPA, Paul Anastas, played a major role in stimulating and defining what had begun to be called green chemistry. As the literature on engineering ethics shows, Anastas’s role must be analyzed in the context of his hierarchical position, where access to legitimacy and financial resources go hand in hand with the systematic subjection of individual action to administrative and political hierarchies. In such institutional settings, an individual can have some influence over their hierarchy, but they can only induce major changes with the support of their superiors and in agreement with the agency’s more general policy background at that given time (Conlon 2019; Swierstra and Jelsma 2006; Lynch 2015).

Drawing the picture of the chemical risk policies at the EPA in the 1990s helps to explain a key contradiction found by Woodhouse and Breyman. The authors noted a difference between the revolutionary messages of GC’s “progenitors” on the one hand, and on the other, their strategy of promotion, which does not criticize “brown” chemistry and excludes participation from civil society or the public. Considering GC as a “science only”—and not as a platform for political discussion about the use of chemistry in contemporary societies—maintains the status quo of “blindly relying on business executives and their technoscientific employees and consultants” (Woodhouse and Breyman 2005, 219) for making decisions about how research and innovation should address pollution. Furthermore, analyzing the policy context in the late 1980s and 1990s allows us to understand why these individual efforts were successful in an institutional setting where an individual, even the most convincing, is only one element of a much larger network of interdependencies with other individuals at different hierarchical levels and in other institutions.

This paper uses primary sources, including nine interviews with professionals who helped draft, shape, and implement the Massachusetts’ Toxic Use Reduction Act ¹ from their respective roles as political advisers and bureaucrats, and with major players in GC at the federal level. Interviewees were mainly identified using the snowball method. The interviews took place in November 2013, during a visit to the United States, and by phone in late 2013 to early 2014. The interviews were recorded (with interviewees’ verbal permission), transcribed, and underwent thematic qualitative analysis (Silverman 2011). As agreed with the interviewees before each interview, the results of the analysis and the citations were anonymized for use in this paper. Secondary sources, in particular, EPA documentation on GC, have also been used to understand the political history of GC. These sources were identified using the EPA’s NEPIS database, using “pollution prevention” or green chemistry as search words. Documents suggested by interviewees are also used.

Unpacking the Political Context: Economic Arguments at the Heart of PP

The emergence of GC is grafted onto PP policy, which was enshrined in federal law with the Pollution Prevention Act (PPA) in 1990. Instead of dealing with pollution as and when it occurs, PP proposes to reduce its production “at the source,” that is, at upstream sources of chemical production processes. According to the PPA (Section 6603(5)),

“source reduction” means any practice which—

reduces the amount of any hazardous substance, pollutant, or contaminant entering any waste stream or otherwise released into the environment (including fugitive emissions) prior to recycling, treatment, or disposal; and

reduces the hazards to public health and the environment associated with the release of such substances, pollutants, or contaminants. The term includes equipment or technology modifications, process or procedure modifications, reformulation or redesign of products, substitution of raw materials, and improvements in housekeeping, maintenance, training, or inventory control.

The concept of PP predates the PPA. In 1975, the company 3M launched the Pollution Prevention Pays (3P) program, which is one of the first initiatives in this area (National Pollution Prevention Roundtable 2003). This program began while the United States was experiencing a real legislative upheaval in the early 1970s, through the adoption of the National Environmental Policy Act, Clean Water Act, Clean Air Act, and Resource Conservation and Recovery Act; the EPA was created in this context too. One year after 3M’s program, in 1976, the EPA mentioned “source reduction” in a document that sought to establish a hierarchy of approaches to managing waste (National Pollution Prevention Roundtable 2003). This term was then used by several US states, featuring in documents such as North Carolina’s Pollution Prevention Pays Program (1983). Source reduction is advantageous because of its win-win proposition: the economic argument no longer contradicts environmental protection and showcases virtuous industry motivations instead.

The PP movement continued to grow in the 1980s, with several large companies implementing similar programs: Dow created the Waste Reduction Always Pays program, Chevron launched the SMART program (Save Money and Reduce Toxics; National Pollution Prevention Roundtable 2003), and Union Carbide applied a policy that required all its manufacturing sites to set up a waste minimization program (US Senate, Committee on Environment and Public Works 1990). The end of the 1970s was also marked by the Love Canal disaster. ² The abundance and gravity of the health effects and the magnitude of the political and financial consequences for the government and the polluting company had a lasting impact on people and budgets. Above all, the events of Love Canal led to the creation of the 1980 Comprehensive Environmental Response, Compensation, and Liability Act, known as Superfund. In accordance with this regulation, polluters must pay for decontamination regardless of the age of the pollution and the regulations in force at the time it occurred.

Most importantly, in 1989, the State of Massachusetts adopted the Toxic Use Reduction Act (TURA) after a conflictual process of negotiation between civil society and local industry. The act aimed to change production processes and raw materials’ management in order to reduce or eliminate the use of toxic substances and ultimately the production of hazardous waste. TURA aimed to reduce the hazardous waste produced by industry in Massachusetts by 50 percent before 1997, through a strategy of making information available to the public and providing technical assistance to manufacturers, thus enabling them to identify improvement opportunities. TURA obligated manufacturers to identify the uses of a certain number of toxic substances included in an official list, and manufacturers who exceeded a certain significant threshold had to submit a report to the Department of Environmental Protection indicating the quantities of toxic substances used, the processes involved, and the amount of waste produced. They also had to submit a plan to reduce the use of listed substances, drawn up by state-approved individuals. Heavy substance users also paid a tax that funded the agency in charge of TURA (O’Rourke and Lee 2004). TURA led to the creation of the Toxic Use Reduction Institute in 1989 as an independent government agency ³ of the Commonwealth of Massachusetts, which keeps abreast of scientific advances and provides assistance to companies and certified planners.

O’Rourke and Lee (2004) showed how TURA modified the perspective on the state’s role in environmental policies by stating that “command and control” had evolved into “command and innovate.” The law has provided constant support that has allowed companies to maintain their learning effort over the long term and to focus on specific and measurable objectives. Between 1990 and 2005, TURA led to a 40 percent reduction in the use of toxic substances by the companies concerned. TURA was as much an environmental as an economic policy. It supported an alternative model of industrial activity that accounted for environmental concerns upfront in the production processes, which was minority and out of step with the model defended by big industry. This aspect of TURA may be the reason for its continued opposition by representative structures of the chemical industry, despite positive economic effects on some companies. Although other US states later proposed similar regulations, including successfully New Jersey and Oregon, none were as comprehensive or ambitious as TURA. The national chemical industry quickly organized itself after the Massachusetts experience and began intense lobbying campaigns that significantly reduced the chances of success for similar bills. As one Massachusetts regulator recalled: “They put us the argument that toxic use reduction is bad for chemistry.…I mean…they lied, they all did…. At one point, I went into a situation where they put up a periodic table on a big screen and said: toxic use reduction is going to knock all of these elements…lots of fun. They tried to defund the program, to stop the program” (interview with Massachusetts toxics regulator; the “program” refers here to TURA). Smith (1992, quoted in Freeman et al. 1992) also reported repeated attacks by the chemical industry on the concept of toxic reduction, writing that “companies have been waging a major attack on the concept with fact sheets, position papers, and speakers aplenty. Industry is doing its best to convince Congress that mandated TUR could put an end to life as we know it.” The same text cites a position paper from the Chemicals Manufacturers Association, ⁴ which presents an apocalyptic view of the effects of a regulatory reduction of toxics. The paper invokes “dramatically high” prices for food, a humanity deprived of products that heal or that are needed for transport. Just one year before TURA's 1989 adoption, as a means of expressing its opposition to a regulatory mandate, the US chemical industry had launched its own voluntary approach, termed as Responsible Care. PP was among the core concepts of this program. It is in this context that the PPA became federal law, one year after TURA, with ambitions and means of constraint that had been considerably reduced in comparison to those in the Massachusetts Act. The EPA has been subjected to many pressures since its creation, including repeated legal action, close scrutiny by federal government, a deregulatory political environment, and intense lobbying by industry. These have all weakened the agency and its policy line that polluters’ must respect strict standards under penalty of sanctions (Brickman et al. 1985; Demortain 2020). This context was further complicated by the Toxic Substance Control Act’s structural deficiencies, in particular, the EPA’s ability to request information from industry, which had been included in the legislation since its adoption in 1976. Many directly involved in that legislative process describe a compromise that significantly downplayed its original ambitions and even rendered it inefficient. In Donald Elliott’s account, “a compromise was struck, and the compromise that was struck was to build into the statute a number of provisions that make it very difficult to use” (Chemical Heritage Foundation 2010).

The 1991 asbestos case established a very high level of proof into the jurisprudence and confirmed the TSCA’s inability to push toxics out of the market (Driesen 2005; Franklin 2014). For Clarence Davies, the author of the first version of TSCA:

Well, the agency spent ten years, and God knows how many millions of dollars analyzing asbestos…the case against asbestos was better than it’s likely to be on anything else. Despite that the court said, “no, you don’t have enough evidence to support a ban on asbestos.” The way the court got to that made it clear that there was no humanly possible way to meet the legal criteria that were in the act. I mean, it’s stupid to try, because if you took the court’s verdict as the final word, then you were never going to regulate an existing chemical under TSCA. (Chemical Heritage Foundation 2009)

Furthermore, the EPA’s activity was persistently shadowed by questions about the costs of environmental regulation. Between 1980 and 1990, a series of reports prepared the economic argument for the PPA. A first report on this subject by the US Congress’s Office of Technology Assessment (OTA) was published as early as 1983. In 1985, the Congressional Budget Office published another report on the relationship between environmental regulation and economic efficiency, which begins by noting that “since the passage of major environmental legislation in the early 1970s, the US private sector has spent hundreds of billions of dollars in efforts to comply with regulations intended to control pollution and maintain and improve the quality of the environment” (US Congress, Congressional Budget Office 1985). Another example of this concern for the economic costs of environmental protection was the 1986 OTA report (US Congress, Office of Technology Assessment 1986) focused on PP. The starting point was financial: they note that two thirds of the US$70 billion spent annually on pollution control in the United States were borne by the industry. One of the objectives of reducing toxics at source was therefore to prevent an increase in these expenses over time. A variety of figures supported the argument for the economic inefficiency of environmental regulations: “about $10 million for every page of Federal environmental statute and regulation” (US Congress, Office of Technology Assessment 1986, 8). However, the report did not describe the benefits of PPA regulation in terms of avoiding health effects of toxics. The EPA itself delivered its mea culpa by estimating that it had imposed US$1.4 trillion in compliance costs since its inception in 1970. Public agencies and businesses were said to have spent about US$120 billion annually (2.1 percent of gross domestic product in 1990) in pollution treatment and control measures. The solution is PP to increase efficiency while reducing costs (Feinsten Kareff 1995).

The Adoption of the PP Act and Its Implementation by the EPA

In 1988, the EPA began funding the Pollution Prevention Research Program, which was intended to encourage the development and demonstration of PP techniques. With William K. Reilly as Administrator of the agency, PP gained prominence and was eventually adopted as an overall strategy for EPA action (Burnett 1998). The agency first proposed a PP policy in 1989 (US EPA 1989). The PPA was signed in October 1990, under the presidency of George Bush Sr. Among other responsibilities, the act called upon the EPA to facilitate the adoption of source reduction techniques by businesses and to create a specific office that would be responsible for PP and hold authority over single-medium program offices responsible for air, water, soil, fauna, flora, and so on.

In January 1991, the EPA published its Pollution Prevention Strategy (US EPA 1991), which reassured regulated industries that PP was not intended to expand the authority of the EPA nor to impose new regulatory constraints. It was simply a means to facilitate voluntary initiatives by the industry and thus reduces the need for the agency to implement restrictive action, for example, through the TSCA. The PP strategy recommended voluntary initiatives be accompanied by strong, binding regulations under existing statutory authorities, but the EPA committed to using these prerogatives in a “flexible” and cost-effective manner. As announced in the preliminary PPA hearings by Julie Belaga, Regional Administrator of the EPA: “The role that the Environmental Protection Agency can play is in offering technical assistance, information, data research, and then supplementing that with economic incentives and grants” (US Senate, Committee on Environment and Public Works 1990, 5).

Proximity to companies was in no way seen as a conflict of interest. Cooperative initiatives were associated with incentives for “the regulated community” (the EPA’s budget request for the year 1994 included a US$33 million increase for PP programs) that sought to remove any need for repression: in short, “a user-friendly EPA.” This political vision reflects the transformation of the relationship between regulators and the regulated, with the former abandoning their desire for control (which was difficult to put in practice anyway) and taking on the role of a well-meaning helper seeking to achieve change by using “carrots” rather than “sticks.” The PP principle represents a transition toward a policy of regular comanagement of risk, which contributed to legitimizing this approach in the public eye.

GC as Comanagement Policy

One of the ways to implement the PPA, and the new comanagement policy more generally, was to support GC. The diffusion of this concept is the result of explicit political will and was achieved by intense networking activity driven by the EPA represented by Anastas as well as several other agency employees of the time. The early 1990s EPA fully illustrates the first characteristic for identifying GC as a comanagement policy (see also the Background section). The pronounced asymmetry of information and material resources between the regulator and the regulated—to the benefit of the latter—is the main incentive for comanagement. Indeed, the agency was in a difficult situation, with its chemical risk management policy at a standstill, as shown above. In accordance with the second characteristic—management is characterized by regulators who are highly sensitive to the economic interests of the regulated—the rise of GC occurred in the context of economic interest. For example, the Workshop on Green Synthesis and Processing in Chemical Manufacturing was one of the first organized by the EPA on “environmentally benign chemical manufacturing” (US EPA 1994) to provide insight into the state of the art on GC. Echoing wider concerns about the financial aspects of environmental protection (its cost to polluters and to the public purse), several workshop contributions discussed the expected economic benefits of various green technologies in chemistry. For example, DuPont’s representative promoted a relationship between technological greening and the economy that explicitly prioritized the latter: “without economic viability a good technical idea is not a technology at all—it is merely a fact or a bit of knowledge” (US EPA 1994, 51). Globally, business promoted a vision of the PP principle synonymous to a marginal regulatory change, which reduced the economic impact of existing binding regulations by promoting voluntary measures. For instance, the costs considered were limited to company accounts, and did not include the societal costs of environmental diseases. As far as the EPA was concerned, adopting an economic discourse to justify its initiatives was tantamount to recognizing the financial priorities of the regulated as their own.

To support the political approach of comanagement chosen by the agency, the meaning of the term GC was progressively constructed at the EPA, after the use of other equivalent terms such as “benign by design.” The first book published by Paul Anastas in the American Chemical Society Symposium Series only mentioned GC briefly in its introduction (Anastas and Farris 1994). The argument about greening was essentially built around the concept of benign by design chemistry, presented as a novelty that significantly changed the research and innovation work. Chemists had always been concerned by two imperatives: ensuring that substances perform a specific function, and reducing the cost of producing them. With the new approach to chemistry, a third criterion was added, namely the effects on health and the environment, to be considered in the design phase of the molecules. ⁵ In short, benign by design meant using three criteria to define the “elegance” of chemical synthesis: “efficiency of synthetic methodology, economically viable, environmentally benign” (Anastas and Farris 1994, 10). The term “benign by design” was abandoned quickly and the term green chemistry began to be used regularly in 1996, but with heterogeneous meanings. Two books published that year (DeVito and Garrett 1996; Anastas and Williamson 1996) proposed two different paths of development for GC—despite the fact that both originated from the EPA (Woodhouse and Breyman 2005). DeVito and Garrett’s (1996) approach, which the agency ultimately ceased to promote, drew its inspiration from pharmaceutical chemistry and proposed to synthesize substances that were adapted to the functioning of living organisms (e.g., designing chemicals that are readily conjugated with glucuronic acid, sulfate, or amino-acids to accelerate urinary or biliary excretion). They advocated for green synthetic chemicals to be either quickly metabolized and fully excreted or not assimilated by the organisms. Other definitions included that developed by Collins (1997), who drafted several principles including the use of renewable resources as raw materials; substitution of toxic molecules, in particular, certain solvents and catalysts; the atom economy, reducing energy use by unit transformation; and a focus on developing renewable energy sources. Many of these principles appeared in Anastas and Warner’s (1998) book, published one year later.

The second path for GC did obtain institutional support and was proposed by Paul Anastas. It continued the work of synthetic chemists by proposing a gradual change based on the substitution of substances, solvents, and synthetic routes—all without having to resort to a thorough knowledge of those substances’ biological fate. Chemists were already used to choosing between several alternatives based on criteria of utility and cost. Continuing with the logic of PP, and in line with the use of pedagogical instead of coercive approaches that characterize comanagement policies (third characteristic), Anastas’s approach was essentially pedagogical: greening chemists’ practices in science and industry could take place with an institutional investment and a great communication effort, even in the absence of quantifiable elements that clearly measured progress toward the goal of environmental protection.

When John Warner, then working for Polaroid, wanted to begin large-scale manufacturing of one of his inventions and started negotiating with the EPA about it, he connected with an old school friend, Paul Anastas, who was working for the agency. This is a good example of “underdetermination” (Lynch 2015): a small event at a given moment in time that significantly influences historical outcomes—in this case, the content of the term GC. This encounter between regulatory and industrial worlds, personified by the two “progenitors” of GC, produced an editorial success in the form of their book Green Chemistry—Theory and Practice, published in 1998 and known for proposing the twelve principles of GC. ⁶ The book is a good illustration of cooperative design between authorities and the chemical industry as well as the academic community. GC was not to be seen as a statement of radical departure from “classic” research and innovation in chemistry. The concept was revolutionary in theory but intended to be conciliatory in practice to account for the contradictory forces at play: on the one hand, the chemical industry’s path dependence and significant investments in existing technologies, and on the other, the political demands of NGOs. To restore the EPA’s legitimacy in the management of chemical risks while avoiding new controversies, the concept of GC had to have a positive, win-win connotation. It would no longer be seen as a constraint but rather as a set of opportunities: new avenues of research, increased economic benefits, a better social image for chemistry, and compliance with regulatory requirements for chemical risks. It was above all crucial to avoid being seen as moralizers, judges, or critics of chemistry. Thus, the book highlighted the continuities between each conceptual and ideological innovation and traditional chemistry.

Nor was there any question of opposing environmental concerns and economic priorities; on the contrary, technical performance relating to environmental impacts was linked to economic performance. Of course, green evokes the environment, but also the United States dollar. The win-win GC equation presumes that if the toxicological properties of a given substance are less detrimental, companies will be freed from a host of obligations: the need to control exposure at the levels more toxic substances require, to set up exposure reduction equipment, and to suffer the financial consequences of toxic effects on employees. Consequently, regulatory compliance would become less expensive and companies could reduce costs. However, this scenario is based on two dubious assumptions: first, that effects suffered by employees or users of substances can be causally and easily linked to company practices and therefore translate into company costs; and second, that regulations were strong enough to impose significant costs on industry, which was therefore obliged to internalize or avoid them.

Both these assumptions being weak, the argument of the economic benefits of GC might not have been very convincing for companies, but fitted perfectly with the political objectives of a win-win chemical policy. GC most benefited the political objectives of an EPA whose effectiveness had come in for public questioning often.

So does this mean that all the changes to research and innovation practices advocated by GC actually changed nothing at all? Given that the underlying objective was to renew relations between regulators and the regulated, what prevailed was less a realistic set of assumptions that could reduce environmental, economic, and social impacts, and more a model of GC that could drive change in the institutional landscape. As Lynch (2015) showed, underdetermination cases such as Anastas and Warner’s encounter and resulting collaboration around GC must be analyzed in light of multiple influencing factors that maintain the trajectory driven by the (small) originating event. If the principles developed by Anastas and Warner became highly popular, it was precisely due to the favorable institutional context at the EPA, and the wider political background. This context may also explain why other definitions of GC developed at the time were less successful. Furthermore, the twelve principles were sufficiently broad so as not to call into question existing social networks around chemical sciences: all synthetic chemists could identify with at least one principle to “green” their work.

GC: Depoliticization through Scientization

The EPA’s strategy for promoting GC illustrates well the sixth characteristic of comanagement: regulators can protect the interests of the regulated when opposed to other stakeholders to safeguard the compromise necessary to this policy approach. The promotion of GC revolved around two main themes: making the idea attractive to industry by showcasing the economic benefits associated with an environmentally cautious approach, while extracting the term from its political context in order to ensure that it did not become an object of social controversy and one that industry would thus avoid at all costs.

In parallel with intensive discussions with the industry, the EPA was working alongside research funding organizations to propagate the term in the academic community. To appear legitimate, GC had to be freed of political connotations and take on scientific neutrality. In 1992, the EPA funded six fundamental research projects through a call for tenders entitled Alternative Synthetic Pathways for Pollution Prevention. However, the academic arbiter in the United States is the National Science Foundation (NSF), whose funding is a marker of academic success. The EPA began to work with the NSF, and in doing so made it possible to include GC in a register of scientific legitimacy. The EPA–NSF partnership led to a research program that made its first call for projects in 1993. In 1994, the EPA–NSF partnership targeted the environmental science research community, with GC included in a call for projects entitled Technology for a Sustainable Environment. Over the following decade, the program funded projects for over US$50 million in “innovative interdisciplinary research in green chemistry, green engineering, and industrial ecology at universities throughout the U.S.” (US EPA 1996, p II).

In the communication about GC at the EPA, it was essential to separate the term green chemistry from its political roots. When reflected in the GC terminology, the eminently political character of the pollution problem was highly likely to trigger controversy, which would have deterred the chemical industry and chemists from adopting it. Yet the EPA’s purpose was to renew its legitimacy on chemical risks, which had been weakened by repeated controversies, publicity around the TSCA’s failure, and political and industrial pressure. To achieve this goal, Paul Anastas and John Warner’s target audience was academic and industrial chemists—the public was not included. The greatest danger to GC was its potential use in political claims calling for further regulation of the industry, which the latter would have perceived negatively. It was important to avoid NGOs from taking up the term GC to claim changes in chemicals policies. In the words of a major TURA actor: “The result was that the NGO community wanted to use green chemistry in a political way, saying: let’s pass legislations that forces firms to adopt green chemistry. John and Paul wanted it to be a concept acceptable to the industry, and as soon as it became state or government activity, that the industry thinks that it is too political…we don’t want to touch it.” In the same line, a green chemist argued that GC “has become a political discussion.” They continued, “when I started green chemistry, it was a science and had nothing to do with politics. But because the environmental movement now says ‘We should do this because it’s right, we should put the companies out of business because they’re evil,’ all of sudden what started off as science is an ethical battle of good and evil. Now, if a politician wants to fund it, they’re actually subscribing now to a label thing that they don’t want to be associated with.”

One of the factors that decisively influenced the adoption of GC was that in research and development practices, just as in industrial practices, this term made it possible to affirm an environmental stance while allowing substantial flexibility in the actions to be implemented. The fact that GC did not challenge established powers partly explains its increased use in academia (Linthorst 2010). Moreover, organizations advocating GC such as the Green Chemistry Institute chose to fit into much more powerful preexisting structures such as the American Chemical Society. ⁷ This platform within the academic community granted them further scientific legitimacy. By the mid-1990s, GC seemed to have finally become intertwined within the structures it initially wanted to change (Roberts 2005). The interdisciplinary nature of its objectives (particularly with toxicology) eventually faded out when confronted with traditional disciplinary frameworks. Although its original objectives presupposed that chemists and toxicologists (and environmental scientists generally) would work together in molecular synthesis, funding channels had remained disciplinary, and were used to submit GC initiatives for selection by the preexisting decision makers who distributed that funding (Maxim 2018). Through the influence of project funding, and other drivers analyzed by Maxim (2018), the definition of GC diverted from its ambitious ideal of renewal of chemists’ work set on paper by Anastas in the 1990s to get closer to the practices of secular chemistry.

Similarly, without questioning current industrial practices, GC eventually reproduced the same logic that positioned efficiency and cost as the most important performance criteria, consolidating the assumption that greening must necessarily be accompanied by financial benefits. Despite their stated hope to include environmental performance as a new decision-making criterion in chemists’ practice, GC founders’ failure to question the classic relationship between economy and environment affirmed the expectation that green must always be profitable. By ignoring the fact that the financial burden of health and environmental effects is not carried by the polluting companies themselves but by individuals or the public sector, GC turns back into traditional chemistry, as shaped by the economic system that helped create it.

Conclusion: GC as a Tool for the Political Transition from TSCA to PPA

This article has shown that the concept of GC illustrates the EPA’s transition from hierarchical policy designed to control the marketing of dangerous substances (TSCA) toward a comanagement policy promoting cooperation with the regulated industry. According to this political vision, the regulator provides technical and financial support to the regulated, in an essentially pedagogical approach, to progressively change mentalities and practices for the better.

Through the notion of design (Demortain 2020), we can understand GC as a legitimation tool, born from the EPA’s need to resist political and industrial pressures and respond to its controversial chemicals policy. Furthermore, foregrounding design helps explain why scientization was so important for the promoters of GC, and why they invested their efforts in partnerships with academic and industrial communities, and not with civil society and the general public. Indeed, strong political revendications of the last might have compromised the industry’s willingness to adopt GC as a term.

Building on the definition of comanagement in Maxim and Berger (2020), we have seen that the 1990 PPA is the result of a pronounced assymetry of information and resources between the regulator and the regulated in favor of the latter (first characteristic). The TSCA’s structural deficiencies and the asbestos trial prevented the EPA from banning toxic substances. In this situation the EPA adopted a pedagogical approach to promote strategies that could be accepted by manufacturers (third characteristic). However, unlike comanagement of chemical risks in Europe (Maxim and Berger 2020), a binding approach as a last resort was not implemented in the American legislation: the PPA provided no binding means of enforcement. The choice was also made to avoid any clear method for measuring the performance of GC. “The shadow of the hierarchy” (fourth characteristic) allows the European Chemicals Agency to maintain some power and cause industry concern about the possible implementation of coercive measures (Maxim and Berger 2020). Yet the shadow of hierarchy did not exist under the TSCA anymore, or under the PPA, in the United States. The history of GC illustrates well the attention the regulator pays to the economic stakes of the regulated (second characteristic). The regulator is responsible for protecting the interests of the regulated against the demands of civil society (sixth characteristic). The technical supports defining the content of GC and proposing methodological avenues facilitate coordination with the chemical industry (fifth characteristic). In all, from the standpoint of regulators, the use of the GC terminology perfectly responds to the huge challenges of managing chemical risks: low public resources available for producing information on the hazards and exposures to toxic chemicals resulting in high levels of uncertainty, a very powerful globalized industry to regulate, a generalized concern about economic performance, and the need to account for conflicting demands from industry and civil society.

Taking a fresh look at the political origins of GC provides a better understanding of the meanings of this term in the academic community and in industry, and more specifically at GC’s interdependence with research and environmental policy drivers. The analysis of the policies behind GC has made it possible to explain why GC followed a similar path to that of brown chemistry, despite alternative proposals for more revolutionary approaches (e.g., DeVito and Garrett’s book was closer to pharmaceutical chemistry). My analysis sheds light on why Anastas and Warner’s definition was successful, while other contemporary definitions were not adopted. As GC was an expression of the EPA’s willingness to compromise with industry to revive its chemical risk policy, it was critical that all concerned adhered to the concept before attempting any theoretically possible changes in chemistry practice. As a tool for sharing policy development and implementation with the regulated, GC could adapt to this relationship and allow the interests of both risk co-managers—that is, the regulators and the regulated—to be considered.

This paper has argued that political drivers were crucial to the emergence of GC and allowed specific technoscientists to build a discourse about its content and evolution. Awareness of this political determinant is essential if we wish to see GC truly move toward responsible research and innovation in chemistry, and not be used for corporate or scientific greenwashing. If left without significant political support in the hope that motivated individuals will continue to carry it forward, it is possible that GC may simply dissapear or become an empty framing for brown chemistry.