Why SSbD Requires a Stronger Alignment Between RA and LCA

The European Commission’s SSbD framework is built on a stepwise approach that begins with hazard identification and moves through exposure-driven risk assessment before integrating life cycle sustainability considerations. As shown in the framework diagram in the slides (page 3)  , the methodology spans:

• Hazard assessment (Step 1) based on CLP and REACH regulatory principles
• Risk assessment (Steps 2 & 3) to ensure safe use for workers, consumers and ecosystems
• Life cycle assessment (Step 4) to quantify broader environmental pressures
• Socio-economic assessment (Step 5)

However, RA and LCA are underpinned by different philosophies:

• RA is threshold-based: below PEC/PNEC or DNEL, no adverse effect is expected (page 5)  .
• LCA is additive: any emission, however small, increases the toxicity score (page 6)  .

This divergence creates inconsistencies for innovators trying to design safer chemicals: a substance can be “safe” in RA terms yet perform poorly in LCA because even trace emissions contribute to the toxicity footprint.

To reconcile this, a minimum prerequisite is to ensure that both RA and LCA rely on the same curated chemical property datasets and follow coherent rules for data selection and quality.

Using REACH Data to Build a Common Evidence Base

During my years at the JRC, one of our major contributions was to systematically extract, curate and harmonise ecotoxicological, human toxicological and physico-chemical data from the REACH registration dossiers. 

• Processing more than 13 million raw data cells from REACH Excel files 
• Applying transparent rules—implemented in R code—to extract a single robust value per endpoint.
• Aligning data interpretation with REACH guidance and Plant Protection Products regulation to ensure regulatory consistency.
• Distinguishing acute vs chronic values through clear criteria  and selecting measured over nominal concentrations when possible .
• Defining four quality levels for ecotoxicity data, covering up to 4226 substances depending on the criteria applied .

More than 82% of the original endpoints had to be discarded due to insufficient reliability, highlighting the critical importance of rigorous curation.

The output of this effort became the backbone of the USEtox effect factors used in PEF and SSbD assessments, relying on chronic EC10-equivalent SSDs and new robustness factors .

A Publicly Available Resource to Support SSbD

Since 2018, the curated dataset and the methodology have been available on the European Platform on LCA (EPLCA), providing companies, authorities and academics with:

• Ready-to-use ecotoxicity data
• Chronic SSDs and HC20 values
• Effect factors for freshwater ecotoxicity, human toxicity cancer and non-cancer

This database was a major milestone in bridging RA and LCA because it ensures both communities rely on the same scientific evidence, curated with traceable rules.

Complementing EU Data With Global Initiatives

To enhance chemical coverage and reflect global scientific consensus, this effort must be expanded by incorporating:

• The US EPA ECOTOX database ,
• The RIVM curated datasets,
• Community-led databases such as EnviroTox and Adore,
• Peer-reviewed literature.

These sources provide essential complementary information, especially for substances with limited REACH data or for emerging contaminants.

Conclusion: A Foundation for Better Decision-Making

The presentation underscored a simple but powerful message: SSbD can only succeed if RA and LCA work with the same high-quality data foundation. The curation and harmonisation of toxicity and chemical property data is not just a technical challenge—it is a strategic enabler for Europe’s green transition.

By aligning methodologies and anchoring assessments in REACH and EFSA evidence, we improve:

• Robustness of hazard and risk assessment
• Consistency in LCA toxicity indicators
• Trust among regulators, industry and stakeholders
• Design decisions for safer and more sustainable chemicals

This work continues today through Net-Zero Impact, supporting organisations that want to operationalise SSbD, strengthen their chemical sustainability strategies, and develop greener products grounded in solid science.