While cosmetics manufacturers have long been required to identify ingredients on the product label, similar regulations do not exist for other formulated consumer products like cleaning products. Product formulation information, including the ingredients used, is often valuable intellectual property that must be protected to some extent in order to sustain a company’s brands. As such, a tension often exists between the desire to release more product information and the need to protect intellectual property. This has led companies to more closely examine where such protections are absolutely necessary and where more ingredient and safety information can be made available to the public.
The result: an unprecedented array of voluntary sharing of product information during the past decade and a half.
Members of the American Cleaning Institute, makers of most of consumer cleaning products in the US, have long been committed to product stewardship, including public sharing of product safety information. Our members were early supporters of the US and global High Production Volume (HPV) Chemical Challenge programs, ultimately sponsoring nearly a third of the chemicals in those programs. As a result, complete hazard data sets for hundreds of the highest volume chemicals around the globe have been made publicly available. Moreover, ACI members took those dossiers a step further by including an exposure assessment and screening level risk assessment.
More recently, our members committed to voluntarily provide product ingredient information, much in the same way ingredients are listed for cosmetics.Now consumers can find an ingredient list for hundreds of products manufactured by our members on product labels or product websites. The vast array of product information now available presents a tremendous opportunity for our industry.
For the first time, it will be possible to have a complete safety story for every ingredient in every product manufactured by our members. That was our vision—to make a complete safety profile for each chemical used in our members’ products publicly available in one place.
This effort, dubbed the Cleaning Product Ingredient Safety Initiative, will take multiple steps and several years to complete. We began in 2012 by compiling a list of ingredients used in our members’ products from a survey of over 900 products. The result is the ACI Ingredient Inventory, which contains a universe of more than 900 unique ingredients identified in consumer cleaning products in the U.S.
The next step—to be completed in the coming year—is to identify a complete, publicly available hazard data set for each of the ingredients on the Ingredient Inventory and to provide a direct electronic link to that information. This will be followed by an exposure assessment for each chemical used in each product and a screening-level risk assessment comparing the threshold for the identified critical hazard endpoint to the exposure.
Based on our previous experience with other large HPV chemical categories, we expect to see similar wide margins of safety for these chemical uses, something our members have long known.
Now the information will be in the public domain, in one place, for all stakeholders–academics, regulators, public interest advocates, and consumers – to consider and critique. As a result of this initiative, we believe we can tread a path that makes good business sense in satisfying regulators’ questions in advance of their asking them, thereby avoiding unnecessary regulations which come with additional compliance costs and often other unintended negative consequences.
In addition, we are building public confidence in our industry by providing unprecedented transparency. We expect others (who haven’t already) to follow suit as demands for product information are not likely to wane.
About the Author Paul DeLeo, Ph.D., is ACI’s Senior Director of Environmental Safety. More info: www.cleaninginstitute.org