CMM Ingredient Disclosure
Imagine that you are a building service contractor 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 season. As part of the
RFP (request for proposal), all cleaning chemicals selected for use in the
schools must be Green certified by a major Green-certification
organization.
The fall season arrives. You have added staff to service the schools and as
required by the contract, all 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
season. Placed at the top of the list, although no one suspects they could
be the culprit, are the Green cleaning chemicals.
However, 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 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.
Full Disclosure
Although this is an imaginary scenario, “it can happen; in fact it probably
has happened,” says Stephen Ashkin, President of The Ashkin Group 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 day-care-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
Ashkin says that in some cases cleaning contractors and end users should
already have this information available to them on the material safety data
sheets (MSDS) that accompany all professional cleaning chemicals.
“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.”
In our earlier scenario, the ingredient causing the respiratory problems was
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
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, 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
(for example, their ability to lower the amounts of specific ingredients to
sacrifice a bit of performance in order to lower costs) 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 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.”
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.”**
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 Consumer Specialty Products
Association (CSPA) that are working to develop just such a system.
Whether this will come about through legislation or voluntary, industryadopted good practices we do not know yet. However, I do believe some
type of full disclosure program is inevitable.”
By xxxxx
*Source: Consumer Specialty Products Association (CSPA)
**Intellectual property refers to “creations of the mind, inventions, literary
works, symbols, images, and designs.” They are treated as property of the
person or organization that created them and can be protected by various
trademarks, copyrights, and laws.