The Subjectivity Of Product Labeling
Imagine that you are a building service contractor (BSC) in a major metropolitan area and your company has won the contract to clean all of the public schools in the district beginning with the next fall semester.
As part of the request for proposal (RFP), all cleaning chemicals selected for use in the schools must be green certified by a major green-certification organization.
The fall semester arrives, you have added staff to service the schools and, as required by the contract, all of the chemicals you are using in the schools are green certified by a leading certification body.
However, after about three months, some of the children in the elementary schools begin experiencing unusual respiratory problems — coughing and wheezing never noticed before, which seems to start a couple of hours after they enter the schools and begins to go away a couple of hours after leaving.
Teachers become concerned, parents become alarmed and, eventually, public health officials step in to find out what could be causing the reaction.
Although there are scores of possibilities, the health officials ask what changes in school operations have been made since the last school year.
Placed at the top of the list, although no one suspects they could be the culprit, are the green cleaning chemicals.
But, because everything has to be investigated, researchers analyze the chemicals in a laboratory to see if they might be causing the respiratory problems.
Sure enough, they discover an ingredient in one of the restroom products that, although it meets green criteria, is known to cause negative respiratory reactions in some children.
The specific ingredient is not indicated on the product''s label nor is it mentioned on any marketing materials.
You replace the problem product with another cleaning solution that does not contain that ingredient, and within a relatively short time, the problem subsides.
Although this is an imaginary scenario, it is entirely plausible.
"It can happen; in fact, it probably has happened," says Stephen Ashkin, president of The Ashkin Group LLC and the industry''s leading advocate for green cleaning. "And, it all could have been avoided, protecting [the children''s] health and saving the contractor a lot of money if that one ingredient had been noted on the product''s label."
This is why Ashkin and others in the industry are now calling for "full ingredient disclosure" of chemicals, green or not.
"The most obvious reason for this is that end customers should know what is in the [chemical] products they select for cleaning. With this knowledge and knowing where the product will be used, the astute distributor [in the scenario above] would likely recommend another cleaning chemical instead."
Some of the other reasons Ashkin advocates full ingredient disclosure are the following:
- To identify chemicals and their ingredients that might meet a specific need, such as protecting the health of small children in daycare-type settings
- To identify ingredients that, while environmentally preferable, may still pose a health concern for some individuals
- To note products and/or ingredients that, while effective and green, may not be best suited for a medical or educational facility
- To help allow end-users to select the safest product among the green-certified alternatives that perform.
"However, the MSDS does not necessarily report all ingredients in the product but only those that might potentially be hazardous or hazardous above specific thresholds," asserts Ashkin.
In our earlier scenario, the ingredient causing the respiratory problems was either not considered hazardous or it was not above recommended thresholds. As a result, it was not disclosed on the MSDS.
The Manufacturers'' Point Of View
According to the Consumer Specialty Products Association (CSPA), current U.S. federal law requires that a product manufacturer must include label information only about a product''s potential hazards, ingredients contributing to those hazards, appropriate handling and storage and applicable first aid information.
Taking this just a step further and listing all product ingredients should be relatively easy. However, there are stumbling blocks.
"Many chemical manufacturers are concerned about listing all of their product ingredients," says Mike Sawchuk, vice president of Enviro-Solutions Ltd., a leading manufacturer of green cleaning chemicals, which does have a full ingredient disclosure policy in place as applicable. "There is the concern that one of their competitors could readily introduce a competing product at a lower price if all the ingredients are disclosed."
Sawchuk adds that many manufacturers determine the charges for cleaning chemicals based not only on the ingredients and costs to manufacture them but also on all the time, research and expense to develop them in the first place.
"If competitors can easily mimic the product [by knowing the product ingredients], they do not have these expenses, allowing for a more competitive price," points out Sawchuk.
Sawchuk suggests that manufacturers should become more transparent and share ingredient information with the end customer.
"But, that does not mean they must divulge intellectual property (IP). Without some protections [for IP], the incentives to develop new products will dry up," notes Sawchuk.
Although Ashkin believes end customers have a right to know what is in the chemicals they select, he agrees that some sort of checks and balances are needed to protect IP, protect the developers of the product and encourage product innovation.
"There are organizations such as the CSPA that are working to develop just such a system," concludes Ashkin. "Whether this will come about through legislation or voluntary, industry-adopted good practices, we do not know yet. However, I do believe some type of full disclosure program is inevitable."
Dawn Shoemaker is a researcher and writer for the professional cleaning, education, health care and hospitality industries. She can be reached at firstname.lastname@example.org.