Saturday, April 11, 2009

Cleaning Products Coming Clean - What Really Is In Windex?

Sure, we all know what is in Windex. Right? Isopropanol, 2-Butoxyethanol, Ethylene glycol n-hexyl ether, Water, and Ammonia. Well, now you can go to a new web site set up by S.C. Johnson & Son Inc. called to describe most of the ingredients for its Windex cleaner, as well as for its Glade, and Shout brands.

The company is part of a recent trend. Other manufacturers of household cleaning products have begun disclosing the chemicals in some of their products. For example, Clorox Co. lists ingredients for its Formula 409 and other products at Seventh Generation Inc., which has long disclosed most of the ingredients for its eco-friendly cleaning products, last year started explaining chemical names in terms that consumers can better understand on its labels. And Procter & Gamble Co. plans to list its ingredients online and describe them in consumer friendly terms.

S.C. Johnson announced in March that they would disclose the ingredients in all of its home cleaning and air cleaning products. If you go to the S.C. Johnson site, for example, you can see the breakdown of its Windex Outdoor Multisurface Cleaner in terms of what each chemical does. Mostly it is Water, of course, but also listed are: 2-(8-Methylnonoxy) Ethanol (Cleaning Agent), Sodium Xylene Sulfonate (Wetting Agent), Sodium Citrate (Stabilizer), and Sodium Carbonate (pH Balancer). The plan to disclose ingredients includes products with fragrances, which generally have been closely guarded trade secrets. Other companies are less sure about doing this, because it is confidential business information; they would prefer a general category called "fragrances, dyes and preservatives." But S.C. Johnson says they prefer the "palate approach" that would give consumers all the information they need to make choices.

The move is not purely altruistic. Consumers have been asking for more information on ingredients in terms they can understand. So in a sense, companies are responding to market pressures. But they are also responding to pressure from advocacy groups who are pressing for greater disclosure. Environmental Working Group, for example, has been visibly campaigning against the use of phthalates in products, and this disclosure will make their use more obvious (and thus likely increase demand for their removal). While both FDA and European regulators have approved the use of phthalates and the industry says they are safe, personal care products are being forced by public insecurity to reformulate their products. Other groups are also pressuring industry to list all their ingredients. A lawsuit filed in February by EarthJustice on behalf of several environmental groups seeks to force Procter & Gamble, Colgate-Palmolive, Reckitt-Benckiser (makers of Woolite), and Church and Dwight (makers of Arm and Hammer products) to list all of their ingredients.

All of this ties in with other programs that seek greater disclosure of ingredients and their health and safety, such as REACH in the EU and TSCA reform in the US and worldwide Ecolabelling efforts. California's development of a new "Green Initiative" will also exert pressure to both disclose their ingredients and show that they are safe. Those companies that lead the way will likely gain market share as consumers more and more focus on products they feel are more sustainable.

These efforts are receiving a boost from industry trade groups that recently set up joint guidelines to encourage use of a standardized format for presenting the technical information. "Consumers want to know more to ensure the safety of their family," says a Procter & Gamble spokesman. "The industry is changing along with that."

Wednesday, April 8, 2009

Chemical Control Reform - Kids Safe Out...ChAMP In?

As discussed here previously, the US is taking a hard look at its 30+ year old chemical control law, the Toxic Substances Control Act (TSCA). Many argue that the law is outdated, both because it doesn't require health and safety data for new chemical notifications and because the bar for regulating existing chemicals seems too high a hurdle. Around 63,000 existing chemicals were grandfathered onto the TSCA Inventory with no health and safety review, and only a handful have seen such reviews since.

Options abound. Should the US pursue a system more like the new chemical control law in Europe, called REACH, which requires that manufacturers and importers of all chemicals - existing and new - provide a dossier summarizing health and safety for all intended uses? Or something more like the Canadian prioritization review and management program in which the government does the hard work of the initial screen for all existing chemicals? Or something like the Kid Safe Chemical Act that has twice been introduced by the US Congress before?

This week at the annual GlobalChem chemical industry conference being held in Baltimore, MD, Jim Jones, EPA's acting toxics and pesticides chief, told attendees at the GlobalChem chemical industry conference in Baltimore, that at the office's first meeting with new EPA Administrator Lisa Jackson, she told staff that “‘ChAMP is fine, but I want to see more, more quickly.’”

ChAMP is the current semi-authorized by TSCA mechanism that EPA has been using to maximize the value of the reams of data received under the voluntary HPV Challenge program between 1998 and 2008. But ChAMP goes further, with proposed enhancements that would "reset" the TSCA Inventory, look at moderate volume chemicals, and inorganic high production volume chemicals that were excluded from the original HPA Challenge.

Jones' comments signal that EPA may be leaning toward TSCA Reform that mirrors more the ChAMP program than the Kid Safe Act. Environmental and health advocacy groups have favored the Kid Safe Act because it puts the onus on producing data on the manufacturers of chemicals, similar to REACH in the EU. Industry favors something more like ChAMP, which initially would require more Agency effort during the screening process, but may provide for a quicker review and prioritization. Once chemicals are prioritized for more in-depth review, industry would provide specific data focused on addressing any real or perceived concerns.

Jackson has hinted on more than one occasion since taking office that she favors the current chemical management system as a basis for reforming the program. The ChAMP program was initiated following former President Bush's commitment to complete the characterizations of Inventory chemicals by 2012 as part of the 2007 Security and Prosperity Partnership agreement with Mexican and Canadian officials.

Officially though, the administration has not yet taken a position on TSCA reform, but Jones suggests that "the administrator is “very interested” in the issue and has discussed the issue “with her small political team several times.” Meanwhile, EPA will continue to use its existing TSCA authorities to regulate substances that are of concern. While Congress is mulling the future of TSCA, EPA has been more assertive in using such TSCA authorized tools as test rules and enforcement actions. It also has been very busy reviewing the data received from the HPV Challenge and issuing hazard and risk prioritizations.

Monday, April 6, 2009

Ten Replies...Advocacy vs Science (From Helicity)

I came across a very interesting blog called Helicity that was replying to the replies of a climate change skeptic (to his earlier post). I thought many of his responses were both patient and insightful, and it's a topic I have covered myself. For those (like me) who aren't familiar with it, helicity is a meteorological term that, "in the most general sense, illustrates to what extent a fluid flows in a corkscrew manner. It’s used in forecasting the likelihood of tornadic development through the Storm Relative Helicity scale (SRH)." The blog's author, "Daniel ‘counters’ Rothenberg, a student of Atmospheric Science at Cornell University," uses helicity as a metaphor for the wild spinning of academic and everyday life.

It's a long post, and I highly recommend you read it. I hope Daniel won't mind that I've included a couple of excerpts here that I found interesting.

Regarding consensus:

"What does “consensus” mean? It means that the people that actually do climate science generally reach the same conclusions and interpretations of the data they work with. In climate science, there is a strong consensus that AGW is the best interpretation of the pertinent data. What this response fails to hit almost entirely is that it’s not the consenus that matters; it’s how that consensus came to be. In the case of climate science, AGW continues to be supported by new lines of evidence. It allows us to answer questions, but also to ask more questions. The important thing is that ain’t nobody done gone and knocked AGW’s knee-caps out! There is a consensus precisely because not only is AGW the most robust explanation of the data out there, but no one has come and falsified it yet."

Regarding peer-review (or lack of it):

"You know, when a skeptics scientific thesis can thoroughly be debunked and refuted in a short, few-paragraph blog post, is it any wonder that it can’t pass the muster of peer-review? Peer-review is far from a perfect, flawless process, and it certanly can insulate the scientific establishment from major changes - even changes which prove to be necessary. But the issue isn’t politics in the peer-review process; it’s flawed science wasting peer-reviewers time."

Regarding refuting data:

"If someone has a serious issue with the latest Mann paper (or any paper in the climate science literature), then it’s about time that they draft a formal refutation and publish it. I can guarantee that if the refutation is legitimate, it won’t have any problem making it into a respected journal. If skeptics are really sitting on AGW-shattering calculations and have better theories formulated, then they need to start publishing them. The problem is that they don’t."

As I said, these are only excerpts from the Helicity post. I recommend reading it in its entirety.

[And for those who are easily confused...this is a blog, so it isn't science, merely an opinion about science.]

Sunday, April 5, 2009

European Trade Union Lists 306 "Substances of Very High Concern" - Will this Blacklist Safe Chemicals?

The European Trade Union Confederation (ETUC), based in Brussels, published a "Trade Union Priority List for Reach Authorisation," featuring a list of 306 chemicals that ETUC says “are of very high concern.” ETUC is calling on European Union (EU) member states to include the list of 306 chemicals on the candidate list of substances for authorization under the EU’s Registration, Evaluation, and Authorisation of Chemicals (REACH) program.

As I have noted previously, REACH is the new chemical control law in Europe and it requires all manufacturers and importers of chemicals to "register" them within a specific time frame if they want to continue using chemicals that have already been on the market. New chemicals must be registered before going on the market, with registration requiring a substantial dossier compiling all of the health and safety data, as well as exposure scenarios for every intended use of the chemical.

In addition to the registration (the "R" in REACH), there is a requirement for certain "substances of very high concern" (SVHC) to receive authorization for continued use (the "A" in REACH). Authorization requires the manufacture to submit an application that includes all of the usual health and safety data in a dossier, and also a plan for its substitution by substances of lesser concern. Authorization is for a limited time and for specific uses only, and only to allow development of alternatives.

Last fall the European Chemicals Agency (ECHA) issued the first of what will be regular lists of "candidate" chemicals, i.e., those substances for which Authorization will be necessary of the manufacturers or importers want to keep the sustance on the market for a while longer (otherwise, they will simply be banned). The first candidate list contained 16 chemicals.

While only ECHA is responsible for issuing the candidate list, other organizations have jumped on the "list" bandwagon in an effort to suggest chemicals they think ECHA should nominate for Authorization. ETUC is particularly concerned about 191 chemicals identified as causing occupational diseases (e.g., acrylamide, bisphenol A, and formaldehyde). Last year a group of European environmental organizations under the collaboration name ChemSoc issued a SIN List (Substitute It Now) of substances they felt were of high concern. In addition, individual Member States of the European Union can suggest chemicals of particular interest to them.

As noted, only ECHA can issue the candidate lists, but with ETUC, ChemSoc and surely others issuing their own lists there is a definite potential for blacklisting. Even the candidate list itself doesn't say the chemicals listed need to be banned or severely restricted, only that they are in need of a much closer look. Some of the candidate list chemicals will eventually be removed as new information is made available by the manufacturers. But having a list of chemicals that someone arbitrarily says are of "very high concern" can be very damaging to busy as downstream users are hesitant to use chemicals that are being targeted. Compare the several hundreds of chemicals on ETOC's list (306) and the SIN list (200) versus only 16 on the first ECHA candidate list and you can see the potential for blacklisting even before there is any formal evaluation of the data.

ETUC says its goal is to contribute to the practical implementation of the authorization phase of REACH. ETUC says it endorses an approach where risks of certain chemicals are controlled and the most hazardous chemicals are replaced with safer alternatives. While all of the chemicals listed by ETUC supposedly meet the REACH criteria for classification as ‘substances of very high concern,’ (i.e., persistent, bioaccumulative, toxic or carcinogenic, mutagenic, or reproductive toxicants), the ETUC list goes further as it "ranks chemicals by reference to their intrinsic toxicological properties and identifies those that cause occupational diseases which are recognised at EU level.”

We'll see how these independent lists affect the market, which could very well substitute away from chemicals that can be safely used and toward chemicals that may actually have a greater impact on human health and the environment.