Product Radical Transparency Doesn’t Go Far Enough

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Tuesday, January 28th, 2014
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Over the past couple of years there has been a growing movement demanding manufacturers declare the constituents of their products publically.

Schemes such as the ‘Health Product Declaration’ (HPD), developed by a corsortia of industry organisations in the USA and now championed by several US based not-for-profit organisations, require manufacturers to complete full declarations of their products. This in itself is not unusual as it is a prerequisite of any independent eco-label or eco-certification program, but the new initiatives go one step further and require the declarations to be put into the public domain.

While this in itself can only be seen as a reasonable concept, it fails to recognise that just knowing what is in a product is just the tip of the iceberg. Schemes such as HPD assume that people will know what to do with the information when they receive it. The HPD program does not have a defined list of banned or ‘Red List’ products as at least one other does and it seems to assume that somehow the industry as a whole is going to learn how to assess the information and apply the extremely complex knowledge and nomenclature of toxicity to their everyday practice in specifying products.

The actual need in the industry is for assessment rather than transparency. Why should the whole industry have to become experts at interpreting health and toxicity information? Once you get past the black and white ‘ban these really terrible compounds’ scenario (this is simple to check), there are tens of thousands of grey area compounds the safety or non-safety of which boil down to degree of toxicity, concentrations, exposures and indeed risk. The ‘good or bad’ scenario is just way too simplistic.

Some attention has been paid to toxicity within the current industry, such as with Volatile Organic Compounds (VOCs) and formaldehyde emissions. However these have been dealt with not by asking manufacturers to declare the emitting compounds, but by requiring them to provide analysis, in this instance via independent testing.

Expecting the average designer or specifier to understand the complexity that toxicity hazard potential is a function of both dose and exposure is fine conceptually. But does every green professional need to understand that:

  • R-Phrase information in Safety Data Sheets is just the top layer in understanding toxicity impacts and each  individual chemical in a product needs to be considered for the degree of its toxicity as well as the dose and exposure at the time of impact;
  • Safe dose measures used are ‘No Observed Adverse Effect Levels’ (NOAELs) and ‘No Observed Adverse Effects Concentrations’ (NOACs). These refer to tests that determine the lethal concentration or lethal dose (LC or LD) to a given indicator plant or animal, under test conditions, that impact a given percentage of the population. They are not usually, in and of themselves, able to assess the toxicity risk levels of products without measures or systems for exposure and/or the likelihood or risk of a critical exposure;
  • To assess the exposure thresholds, other measures are used;
  • TWA (ppm or mg/m3) is the ‘Time Weighted Average’ concentration for a normal 8-hour workday or 40-hour work week;
  • STEL (ppm or mg/m3) the ‘Short Term Exposure Limit’ is the maximum concentration of a substance (a) for a continuous 15-minute exposure period, (b) for maximum of 4 such periods per day, (c) with at least one 60-minute exposure-free period between two exposure periods, and (d) provided the daily TLV-TWA is met?

The HPD program is a step in the right direction, but it doesn’t go far enough and will never work across the entire industry because for some products and manufacturers, especially those in highly competitive sectors where there are many ‘me too’ type products or the potential for them, the specific ingredient formulation is the essence of the manufacturer’s competitive edge or even whole business. These manufacturers will never publically declare their composition. So why lock into a system that will prejudice some manufacturers or product types with no necessary relation to their toxicity impacts? Such an approach could easily have reverse outcomes by discouraging novel, safe product development.

Independent assessment by experienced third parties operating within internationally accepted Australian standards is far better placed to facilitate the uptake of toxicity as an issue in product selection and specification than just constituent declaration alone.

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