Tag: Formula Facts

Consumers Spur Action on Toxins Like Methylene Chloride

Posted on by Nina Hwang, MPH

It has always been clear to Green Seal that toxic substances such as methylene chloride and 1,4-dioxane have no place in the products used in homes, schools or workplaces – that’s why we have long prohibited these and a long list of other hazardous chemicals in our certified products. 

Growing consumer awareness of the health risks of methylene chloride and 1,4-dioxane, both of which are found in common household and personal care products, has begun to prompt action by the federal government, states and retailers.  It’s encouraging that regulation and market behavior are beginning to catch up with the science on these two toxins. However, setting regulations is a lengthy process, and consumers shouldn’t be expected to police hazardous substances in household products in the interim.  

Green Seal fills a critical market gap by taking a precautionary approach – purposefully setting requirements beyond those of the U.S. federal government to empower consumers to choose the safest products on today’s markets and reward the industry innovators who are moving the market to safer, healthier product chemistry. Let’s take a closer look at the two examples of hazardous chemicals that Green Seal has prohibited for decades in our certified products. 

Methylene Chloride Timeline

Methylene Chloride

In 1993, when Green Seal first launched our standard for paints and coatings, methylene chloride was one of the first chemicals we prohibited. More recently, methylene chloride has made its way into headlines for all the wrong reasons. Earlier this year, two women sued the EPA to ban methylene chloride after their sons died from using products containing this chemical. 

This colorless liquid evaporates easily, and its vapors can be irritating to skin, eyes, and the respiratory tract. Exposure to very high concentrations, usually in areas with poor air ventilation, can result in unconsciousness and death.  Since 1980, there have been more than 60 reported accidental exposure deaths due to the use of paint strippers containing methylene chloride.  

As a member of a class of chemicals called organochlorides, methylene chloride is in the company of other known bad players, including vinyl chloride, the pesticide DDT, and polychlorinated biphenyls (PCBs). Methylene chloride continues to be used because it is an extremely effective solvent. This chemical is used in paint strippers and in the manufacturing processes for other products, including pesticides, plastics, and pharmaceuticals. Consumer products that contain methylene chloride include paint strippers, household cleaners, and acrylic adhesives used by hobbyists.

The European Union voted to ban the use of methylene chloride in paint strippers for consumers and most professionals in 2009, effective beginning in 2010. Almost a decade later, in 2017, the U.S. EPA proposed a similar ban in both consumer and commercial products. The final rulemaking was delayed until March of this year, when a scaled back version was passed, which only bans methylene chloride in consumer products. In the interim, several major retailers – including Walmart, Lowe’s, Home Depot and Amazon – committed to phasing out methylene chloride products due to consumer concerns.   

1,4 Dioxane Timeline

1,4 Dioxane

Green Seal doesn’t only prohibit harmful active ingredients from certified products – we also have strict requirements for any impurities and byproducts that may make their way into a finished product. 1,4-dioxane is a probable carcinogen that has also been prohibited from all Green Seal-certified products since 1993. 

Unlike methylene chloride, 1,4-dioxane does not play a role in chemical products. Rather, it is an unintended by-product of a common chemical reaction called ethoxylation. In this process, ethylene oxide reacts with any number of chemicals, including alcohols, phenols, and polyethylene glycols, to create surfactants and other chemicals. These surfactants are used in cleaning products, laundry detergent, and shampoos to remove dirt and stains. Ethoxylated ingredients are also added to cosmetics as thickeners, skin conditioning agents, and emulsifying agents. Because it is a by-product, manufacturers may not even know if their products contain trace amounts of 1,4-dioxane. 

Twenty-five years after Green Seal first acted to prohibit this chemical, state legislators are beginning to address growing consumer concern about 1,4-dioxane. California now requires that this chemical be disclosed if it is present in cleaning products, even as an impurity. The New York State legislature recently passed a bill limiting 1,4-dioxane to 1 part per million (0.0001%) in detergents and other cleaning products and California has announced plans to consider setting a threshold as well. 

Green Seal and Safer Alternatives

It can be challenging for manufacturers to find alternative substances that are safer for human health and the environment and that still perform to industry standards. Sometimes, in an effort to avoid one substance, the market moves toward regrettable substitutes: N-methylpyrrolidone (NMP), once widely used an alternative to methylene chloride, has its own toxicity issues and has also recently been banned for consumer use by the U.S. EPA and retailers. 

Similarly, manufacturers that want to replace ethoxylated surfactants in their products to eliminate 1,4-dioxane will need to carefully select safer alternatives. Filling in data gaps can prevent the unintentional introduction of a dioxane-free replacement with its own set of health and environmental hazards. 

Consumer demand will continue to drive market change and innovation, especially among market leaders. When you see Green Seal’s certification mark on a product, you can trust that we’ve screened that product against these and all other known hazardous chemicals, and that the alternatives are not known to have associated health and environmental risks.  And because we have strict performance requirements, you can rest assured that these alternatives will still work as you expect them to. 

Will CA Transparency Law Spur Safer Cleaning Products?

Posted on by Doug Gatlin

Growing public demand for ingredient transparency across the marketplace is prompting regulators to require manufacturers and retailers to publicly communicate the ingredients in everything from personal care and baby products to cosmetics and cleaning products.  

Starting this January, cleaning product manufacturers for the first time will have to post their product ingredients online to comply with a new ingredient disclosure law in California. As the nation’s leading environmental certification organization, Green Seal has always required manufacturers to fully disclose their product ingredients to us to qualify for certification. 

We believe that public disclosure of product ingredients can empower purchasers to choose healthier, safer products. But we also know that reading a long and complicated list of ingredients without context can be confusing or even misleading, defeating the purpose of ingredient transparency.

Formula Facts Make Disclosure Easier

To help both purchasers and companies get the most out of the new ingredient transparency law, we recently launched Formula Facts, an ingredient label program that makes it easier for leading manufacturers to provide clear, accurate and meaningful ingredient communications.

But will disclosure finally prompt companies to weed out the stew of toxic chemicals that lurk in most cleaning products?  Here is what we have learned about the benefits and challenges of ingredient transparency over decades of working with the nation’s leading cleaning product manufacturers. 

1.       Manufacturers don’t know all their product ingredients.

Ingredient disclosure is made harder by the fact that cleaning product manufacturers often don’t have access to information about some of their ingredients. That’s because they buy their raw materials from other suppliers who keep their formulas confidential.  Manufacturers know what the raw material will do in the cleaning product (for example: it’s a solvent), but they may not know the specific identity of the active ingredient or whether there are any additives.

Think of it like making homemade cookies with bakery-bought chocolate chips. You know that the chips will taste delicious in your cookie, but you don’t know where the chocolate was sourced or whether any ingredients were added to keep them tasting fresh.

When Green Seal evaluates a cleaning product for certification, we work with the company’s raw material suppliers to track down every ingredient in that product. Because so many of the ingredients in a finished cleaning product are contained within the raw materials and hidden from view to the manufacturer, it will be essential for manufacturers to convince their suppliers to disclose their ingredients — even when they involve confidential business information.  This will only help promote safer product formulations.

2. Some chemicals are hard to detect.

In addition to ingredients that are intentionally added, cleaning products can contain byproducts and other impurities that are unintentionally created during a chemical reaction.One example is 1,4-dioxane, a carcinogen found as a reaction by-product in ethoxylated substances, which are often used as surfactants in cleaning products.

The state laws require manufacturers to identify certain byproducts and other impurities that are associated with harmful health and environmental impacts. But this information can be hard for manufacturers to find because there is no requirement for raw materials suppliers to disclose the byproducts and impurities in their products. These chemicals also tend to be present at much lower concentrations that are harder to detect. Green Seal always screens for byproducts and impurities when we evaluate a cleaning product for certification to fully understand the product’s composition. Often, this process alerts manufacturers to the presence of chemicals they weren’t aware were in their products.Identifying these chemicals is the first step to weeding them out – another win for ingredient disclosure. Communicating product ingredients can help companies increase credibility and build trust with their customers. However, even the clearest ingredient labels can be difficult to decipher for anyone but a toxicologist.

3.       “Chemicals of Concern” are constantly changing.

The ingredient labeling laws require companies to clearly communicate whether their products contain any “chemicals of concern,” which include known carcinogens, reproductive toxins, and other ingredients harmful to human health.  But this task isn’t as straightforward as it sounds. There are dozens of different lists of chemicals of concern, including 22 referenced by the California law.  What’s more, the lists are constantly updated as new studies and information become available about the potential health impacts of the chemicals available in the marketplace.

In order to comply with the laws, manufacturers will have to track ongoing changes to each of these lists and update their ingredient labels accordingly.  In this way, the disclosure laws will force companies to pay close attention to new findings about the health risks of common chemicals.

4.      Ingredients have aliases.

The laws require cleaning product producers to list ingredients in descending order of weight, but even something as simple as communicating an ingredient’s name can be complicated. There are more than 2,000 chemicals used in conventional cleaning products – but an estimated 10,000 names for those chemicals.  For example, the carcinogenic byproduct 1,4-dioxane goes by a number of aliases, including Diethylene Oxide, Diethylene Dioxide, Dioxane, para-Dioxane, 1,4-Dioxacyclohexane, and Diethylene Ether, to name just a few.

Companies will have to follow the states’ regulatory guidelines for choosing the most appropriate names for their ingredients.  However, variations in naming conventions are likely to continue to cause confusion and uncertainty for consumers, who can’t be certain whether the ingredients they are screening for are hidden under aliases.  

5.       Communication won’t do the job of certification.

Communicating product ingredients can help companies increase credibility and build trust with their customers. However, even the clearest ingredient labels can be difficult to decipher for anyone but a toxicologist. Long lists of chemicals can be overwhelming and anxiety-inducing even when the chemicals are harmless.  Consumers can’t be expected to know whether chemical combinations are producing harmful byproducts or whether an ingredient that is considered a carcinogen in aerosol form is benign in liquid form.

When reviewing a product for certification, Green Seal always starts with ingredient disclosure – but that by itself does not translate to safer, greener products.  Disclosure precedes a scientific analysis of the formula information, and then the essential work of filtering out products that don’t meet strict health, safety and performance benchmarks. 

Reputable ecolabel standards stay far ahead of public awareness about the health risks of toxic chemicals.  For example, commonly found toxins like methylene chloride and 1,4-dioxane – which have only recently spurred widespread public concern – have been prohibited in Green Seal-certified products for decades. While ingredient communication itself is not sufficient to transform the market, these requirements often encourage manufacturers to move toward safer product formulations – in effect taking their first step towards environmental certification. With ingredient labels that consumers can access and understand, transparency will continue to spur innovation and guide the economy towards a healthier, cleaner future.

Titanium Dioxide Whitens in Enzyme-Based Cleaning

Posted on by Green Seal

Green Seal has issued new editions of our cleaning product standards with one minor change: We now allow titanium dioxide as an ingredient in enzyme-based products, within certain conditions.

Titanium dioxide is a colorant that is included to whiten and brighten many types of products – from food to paints and personal care products. In enzyme-based cleaning products, like with paints and makeup, consumers show preference for whiter and brighter options and this is why manufacturers see titanium dioxide as a key ingredient.

Titanium dioxide was previously prohibited in all cleaning products because it is classified as a “Group 2B” carcinogen, i.e., “Possibly Carcinogenic” when inhaled1 (and only when inhaled).  Because we’ve seen this ingredient in a wide range of enzyme-based cleaning products, we conducted several health impact analyses and identified a meaningful solution. We developed a set of requirements that ensures that titanium dioxide particles will not become airborne when the product is used. Below we’ve walked through this framework of requirements and summarized our key considerations, but you can find the full technical proposal on our website.

 Our Open and Transparent Process

As always, we published this proposal for public comment and actively solicited feedback during a six-month period in order to ensure that we heard perspectives from all interested groups. This open process and our evidence-based decision-making is at the core of Green Seal standard development.

Green Seal Focuses on What Matters

We take our role seriously as an environmental organization that sets the bar for sustainability and defines meaningful health protections for products and services. We work to advance industries toward healthier, safer, and greener practices, and also to ensure a wide range of certified products so that conscious consumers can have their pick.

In this case, the results of our health impact analyses demonstrated that we could confidently allow manufactures to provide certified products that are formulated with titanium dioxide. With this move, we ensure that these certified products can be just as white and bright as their conventional counterparts while being significantly healthier and greener. It’s a minor change for our standards; this is one of more than 65,000 chemicals that we scrutinize during our certification processes – however, it’s a meaningful change for our product manufacturing community and a reminder that we focus on real-world health and environmental impacts instead of simply checking the boxes.  

 Protecting the Health of the User

In our proposal, we demonstrated that titanium dioxide can be present in an enzyme-based cleaning product without any risk of the product user inhaling this compound.

  • For foam, gel, and liquid products – the product itself does not become airborne. Therefore, we set no conditions on allowing titanium dioxide as an ingredient.
  • For solid products, dust can be generated by the product that could be inhaled during the use phase. Therefore, in order to include titanium dioxide as an ingredient, the manufacturer must provide evidence that the titanium dioxide particles are bound within the product matrix or to bonded to other product ingredients. This protective requirement aligns with the protections stated by the State of California’s Proposition 65 program, which only considers titanium dioxide carcinogenic when it is airborne and unbound.
  • For liquid products, there is an existing Green Seal requirement that states that enzyme-based cleaning products cannot be sold in spray packaging; therefore, we’ve already set requirements that prevent liquid from becoming airborne via dispersed spray and inhaled by the product user.

Within this framework, Green Seal has maintained a strict level of health protections for product users. As always, when Green Seal appears on a product label, consumers can be confident that these products will work effectively, will protect their family, workers, and our environment – and now, thanks to this revision, these products might be a bit whiter.

Update: TCSA (Toxic Substances Control Act) Amendment

Posted on by Green Seal

Recently, Green Seal’s standards development team attended a conference on the Frank R. Lautenberg Chemical Safety for the 21st Century Act, which celebrated its 1-year anniversary. We greatly enjoyed the candid conversations between the heavy hitters: government officials, members of Congress, representatives from industry, and environmental advocates.

The bill was signed into law on June 22, 2016 by President Obama, and was widely proclaimed a success. Soon after the signing, the usual political chatter began: cheers (a rare show of bipartisanship!), grumbles (the law was decades overdue), jitters (could the EPA handle the ambitious time lines?), shrugs and yawns (too many compromises). We, in Green Seal’s Washington, DC’s headquarters, sometimes enjoy the political opera, especially since we remain happily seated in the mezzanine. I, and my friends in the DC environmental community, were heartened by the news: the EPA now had greater authority, strict time lines for progress, and dependable funding sources for implementing effective chemical regulation.

Chemical Safety, The Previous Version

The law is an update and expansion of the 1976 Toxic Substances Control Act (TSCA) (“Ta-Ska”), which defined the federal regulation of chemicals. Unlike the other major environmental legislation of the 1960s and 70s (The Clean Air Act, the Clean Water Act, CERCLA, RCRA, etc.) which responded to pollution and hazardous chemical releases after the fact, TSCA was intended to prevent hazardous chemicals from entering the market. The EPA was authorized and required to track chemicals that were being manufactured or processed, to evaluate new chemicals for health and environmental impacts, and to regulate (restrict, ban or in some way control) those chemicals that were identified as hazardous. TSCA implementation was slow and often ineffective because of legal loopholes, an overworked and underfunded agency, and general disinterest among members of Congress. Pushed to fill what they saw as a public health protections gap, state health departments and legislative bodies established state-wide chemical regulation programs, which sometimes caused confusion and frustration for product companies and chemical suppliers. With a goal of simplifying and re-nationalizing US chemical regulation, TSCA reform became a priority for businesses and chemical manufacturers. From 2009 to 2016, members of Congress, environmental advocates, and industry groups worked on the reform bill, and ultimately passed the Lautenberg Act in the House of Representatives with a vote of 403 to 12, and passed the Act in the Senate with a voice vote.

About the Lautenberg Act (TSCA Amendment)

  • The EPA no longer needs to identify a regulatory action that is “least burdensome” to industry when carrying out a chemical ban, restriction, or exposure reduction measure.
  • The EPA is no longer required to conduct a cost-benefit analysis along with its chemical assessments, and is, in fact, prohibited from factoring in the financial impacts of a regulatory action.
  • The Act requires the EPA to protect vulnerable populations: “”the health of children, pregnant women, the elderly, workers, consumers, the general public, and the environmental from the risk of harmful exposures to chemical substances and mixtures.” One year in, the EPA has made real progress.
  • June 22, 2017: The EPA issued Final TSCA Framework Rules (National Law Review)
  • Announced the scopes of the risk evaluations for the first ten chemicals (EPA)
  • Dozens of new chemical determinations were completed in June 2017 and nearly 1,000 new chemical determinations were completed from June 2016 to June 2017 (EPA – Actively updating the number of completed determinations).

Green Seal’s Chemical Considerations

The ongoing implementation of the Lautenberg Act has had no direct effect on Green Seal, our standard development, or our product evaluation processes. In their chemical assessment process, the EPA is identifying and regulating the most harmful chemicals; Green Seal is defining and validating the qualities of environmental leadership products – that they are formulated with safer chemicals, perform effectively, and have an overall lower environmental and health impact. However, TSCA Reform may eventually lead to a change in Green Seal’s standards. If the floor for chemical safety rises in the US market, we may see a significant shift in the formulations of all products, and further improvements to leadership products. If this shift takes place, Green Seal will update our standards in order to accurately reflect the new levels of leadership.

A Different Level of Scrutiny: While the EPA conducts risk analyses, Green Seal emphasizes chemical hazards. One of our major goals of product certification is to encourage the elimination of hazardous chemicals on the US market.

Identifying New Chemicals of Concern: In our product reviews, Green Seal ensures that products are not formulated with persistent / bioaccumulative / toxic substances (“PBTs”) and one way that we accomplish this is by noting the chemicals of concern that are listed in the EPA’s Toxics Release Inventory. As the EPA gathers and reports the results of toxicological evaluations, new PBTs may be identified, which would better inform our evaluation.

A Clearer Evaluation Process for Companies: Companies with Green Seal-certified products will benefit from a clear and consistent framework for the evaluation of chemical substance and the associated risks, and from the new data that will result from the evaluation process. (Looking through rose-colored beakers…) Perhaps TSCA Reform will also spur green chemistry innovations, increasing the numbers of safer substitutes, and simplifying the process of developing safer formulations.

To learn more about TSCA Reform, the Lautenberg Act, and EPA’s progress since June 2016, check out the following links: