Under section 612 of the Clean Air Act (CAA), EPA reviews substitutes within a comparative risk framework. More specifically, section 612 provides that EPA must prohibit the use of a substitute where EPA has determined that there are other available substitutes or potentially available substitutes that pose less overall risk to human health and the environment. Thus, EPA’s Significant New Alternatives Policy (SNAP) program, which implements section 612, does not provide a static list of alternatives but instead evolves the list as the EPA makes decisions informed by our overall understanding of the environmental and human health impacts as well as our current knowledge about available substitutes.
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