Henkel Department of Ecology Department of Hospital Hygiene Ecological Product Certificate of Skinsan Scrub Foam State: June 2000 Ecological certificate of Skinsan Scrub Foam 2 esssf.doc State: June 00 _____________________________________________________________________________________________________ Ecological Product Certification of Skinsan Scrub Foam State: June 2000 Ecological tests of products are carried out in the ecological institute at Henkel according to official and international OECD test methods. The ecological institute works in accordance with the OECD guideline for ”Good Laboratory Practice” (GLP). 1.0 Field of application Antimicrobial washing foam for hands and body cleaning 2.0 Ingredients Correspond to INCI: Aqua, Propylene Glycol, Sodium Cumenesulfonate, Citric Acid, Ethanolamine, Decyl Glucoside, Sodium Laureth Sulfate, Triclosan, Undecylenic acid 3.0 Overall evaluation When properly used, this product does not enter sewage. However, an ecological evaluation is carried out in order to enable a product evaluation in the case of unintentional discharge. In Germany and in other European countries municipal and commercial sewage is cleaned in biological sewage treatment plants, before it enters into river water. Depending on biodegradability (brake down) or mechanical elimination of substances in the waste water there remains a more or less residual load for the self purification process in the river. For an ecological evaluation therefore information on the biodegradability and elimination are important criteria. The degradability values of all individual organic components are added up, taking into consideration the proportions in the present product (see individual evaluation). It is then determined which degradation value would be obtained if the product as a whole was tested in an OECD test on ready biodegradability. If the limit for classification as "readily biodegradable" is exceeded, this product is classified as "biodegradable". Consequently, the BOD/COD ratio is > 60 %. However, it is still possible that some individual components contained in small quantities do not attain this limit while others contained in greater quantities exceed this limit to such an extent that they conceal the first-mentioned. Ecological certificate of Skinsan Scrub Foam 3 esssf.doc State: June 00 _____________________________________________________________________________________________________ Therefore, we also inform about the quantity of these smaller fractions by differentiating the term "biodegradable" in the overall evaluation. We also provide information if the ingredients are not classified as "readily biodegradable", but are almost as well removable in sewage treatment plants as communal mixed sewage. For these fractions, the BOD/COD ratio is < 60 %. The present product is evaluated as follows: 4.0 - Very well biodegradable - The degradation requirements of the Detergents and Cleaners Act respectively the EU Detergent Directives 82/242 (nonionic surfactants) and 82/243/EEC (anionic surfactants) are largely exceeded - The antimicrobical substances are eliminated in sewage treatment plants Microbicidal effect on treatment plant bacteria For this product, the toxic threshold concentration of sewage treatment plants which must not be exceeded is > 10 - 100 mg/l. This concentration is not attained under normal application conditions in sewage. Concentrates must never enter sewage. 5.0 Packaging material: The package consists of polyethylene or polypropylene plastics. Exclusively produced by brand manufacturers it is made of nonrecycled, new raw materials in order to guarantee the necessary quality, which must be required in the field of medicine and food technology. The cartons consist of natural-coloured, unbleached and largely recycled paper. The adhesive tape locks used consist of polypropylene. These emptied packages can be disposed without difficulty under dump conditions or by combustion. The plastic packages are labelled in order to facilitate recycling of the material. They are inert to ground water and satisfy the requirements concerning the improvement of thermal combustion by avoiding pollutants which impair flue gas utilization as well as heavy metal compounds in combustion residues. Ecological certificate of Skinsan Scrub Foam 4 esssf.doc State: June 00 _____________________________________________________________________________________________________ Evaluation of single ingredients 6.0 Care agent The product contains water soluble alcoholic compounds which are partially synthetic, partially natural. These alcohols are very easily degradable into carbon dioxide and water, and according to the criteria of the OECD they are considered as easily and quickly biodegradable under environmental conditions (terminus technicus: readily biodegradable). Test data - Degradation into carbon dioxide and water: According to the internationally valid criteria of the OECD and the test methods used here, these components are classified as easily degradable (terminus technicus: readily biodegradable) since the limit values according to the OECD are exceeded. (Closed Bottle Test and/or Modified OECD Screening Test: EECDirective 67/548/EEC on the approximation of the laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances (Off. J. 196, 16.08.1967, p. 1) and 6th amendment EEC-Directive 84/449/EWG, Annex V, Part C: Biodegradation.) 7.0 Solubilizer The product contains an aromatic anionic organic compound whose biodegradability is not subject to any legal regulation. Therefore there is no regulation requiring the testing of the primary biodegradability as in the case of the anionic and nonionic surfactants. For the assessment, the mineralization into carbon dioxide and water must be used. This compound is easily and quickly degradable into carbon dioxide and water (readily biodegradable). Test data - Degradation into carbon dioxide and water: According to the internationally valid criteria of the OECD and the test methods used here, these components are classified as easily degradable and classified as readily biodegradable since the limit values and kinetics (10 day-window) according to the OECD are accomplished. (OECD - Guidelines for Testing of Chemicals - OECD 301 A_F: e.g. Closed Bottle Test, Modified OECD Screening Test and/or Manometric Respirometry-Test: EEC-Directive on the approximation of the laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances and 7th amendment EEC-Directive 92/69/EWG, Annex V, Part C: Biodegradation.) Ecological certificate of Skinsan Scrub Foam 5 esssf.doc State: June 00 _____________________________________________________________________________________________________ 8.0 pH-Value regulator Regulator 1 The product contains an organic acids which is very well degradable into carbon dioxide and water. According to the criteria of the OECD it is regarded as easily and quickly biodegradable under environmental conditions (terminus technicus: readily biodegradable). Test data - Degradation into carbon dioxide and water: According to the internationally valid criteria of the OECD and the test methods used here, these components are classified as easily degradable (terminus technicus: readily biodegradable) since the limit values according to the OECD are exceeded. (Closed Bottle Test and/or Modified OECD Screening Test: EECDirective 67/548/EEC on the approximation of the laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances (Off. J. 196, 16.08.1967, p. 1) and 6th amendment EEC-Directive 84/449/EWG, Annex V, Part C: Biodegradation.) Regulator 2 The product contains a nitrogen-containing compound which is very well degradable into carbon dioxide, water and inorganic nitrogen compounds. According to the criteria of the OECD it is classified as easily and quickly degradable under environmental conditions (terminus technicus: readily biodegradable). Test data - Degradation into carbon dioxide and water: According to the internationally valid criteria of the OECD and the test methods used here, these components are classified as easily degradable and classified as readily biodegradable since the limit values and kinetics (10 day-window) according to the OECD are accomplished. (OECD - Guidelines for Testing of Chemicals - OECD 301 A-F: e.g. Closed Bottle Test, Modified OECD Screening Test and/or Manometric Respirometry-Test: EEC-Directive on the approximation of the laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances and 7th amendement EECDirective 92/69/EWG, Annex V, Part C: Biodegradation.) Ecological certificate of Skinsan Scrub Foam 6 esssf.doc State: June 00 _____________________________________________________________________________________________________ 9.0 Surfactants Anionic surfactants The product contains anionic surfactants. These surfactants are very well degradable (primary degradation); their degradability is considerably better than required for the primary degradability of the surface active substances in the EEC-Detergent directive. The primary degradation step is followed by further degradation into carbon dioxide and water (final degradation/mineralization). According to the international criteria of the Organization for Economic Co-operation and Development (OECD) all these substances are classified as "easily and quickly degradable under real environmental conditions" (readily biodegradable). Test data - Primary degradability (loss of washing activity, analytical detectability and surfactant characteristics): > 95 %. Council Directive 73/404/EEC on the approximation of the laws of the member states relating to detergents and amendments for the biodegradability testing 82/243/EEC (anionic surfactants) and 82/242/EEC (nonionic surfactants) - Degradation into carbon dioxide and water: According to the internationally valid criteria of the OECD and the test methods used here, these components are classified as readily biodegradable since the limit values and kinetics (10-days-window) according to the OECD are accomplished. (OECD - Guidelines for Testing of Chemicals - Ready Biodegradability: OECD 301 A-F: e.g. Closed Bottle Test, Modified OECD Screening Test and/or Manometric Respirometry Test: EEC-Directive on the approximation of the laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances (84/449/EEC) and 7th amendment EEC-Directive 92/69/EEC, Annex V, Part C.4: Biodegradation.) Non-ionic surfactants The product contains with Decyl Glucoside a new non-ionic surfactant on the basis of natural raw materials whose biodegradability is not subject to any legal regulation since it does not react as a Bismute-active substance (BiAS) and therefore cannot be measured with the analytical processes provided in the legal regulation (surfactant regulation). Thus the ultimate degradation into carbon dioxide and water (mineralization) is used for the degradation evaluation. This compound is easily and quickly degradable into carbon dioxide and water (readily biodegradable). Ecological certificate of Skinsan Scrub Foam 7 esssf.doc State: June 00 _____________________________________________________________________________________________________ A substance specific analytical method (HPLC) proved very high elimination rates (>99.5%) under model sewage treatment plant conditions. Test data - Degradation into carbon dioxide and water: According to the internationally valid criteria of the OECD and the test methods used here, these components are classified as easily degradable and classified as readily biodegradable since the limit values and kinetics (10 day-window) according to the OECD are accomplished. (OECD - Guidelines for Testing of Chemicals - OECD 301 A-F: e.g. Closed Bottle Test, Modified OECD Screening Test and/or Manometric Respirometry-Test: EEC-Directive on the approximation of the laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances and 7th amendment EEC-Directive 92/69/EWG, Annex V, Part C: Biodegradation). 10.0 Antimicrobical active substances Disinfecting agents are compounds which are destinated to attack microorganisms at specified concentrations. On account of this characteristics they also display their microbicidal effect in the OECD tests on "easy and quick biodegradability" (ready biodegradability), thus obstructing their own biodegradation. Therefore, the test result may be falsified in the officially prescribed tests since the result provides no information about a structure-related good or poor degradability. For the test of microbicides on biodegradability, the tests must be modified in order to exclude such selfinhibitions of biodegradation, e.g. through reduction of the test concentrations or addition of the test substance in small portions instead of the usual single portion with a correspondingly increased concentration. In sewage treatment plants, the organic pollutants are biodegraded by bacteria. These treatment plant bacteria must not be impeded through the disinfectants. Thus, through dilution in sewage, the microbicidal active threshold must never be exceeded in the sewage treatment plant in order to avoid malfunctions in sewage treatment plants and to enable the structure-related possible biodegradation. The data for biodegradability refer to test concentrations below the threshold for toxic selfinhibition. As for the rest, the mentioned tests correspond to the official regulations adopted by the OECD and the EC, as described there. Ecological certificate of Skinsan Scrub Foam 8 esssf.doc State: June 00 _____________________________________________________________________________________________________ Triclosan This component is a microbicidal organohalogen, with – because of its activity against bacteria - only low biodegradability performance in the OECDscreening-tests for ultimate biodegradability. Nevertheless a biodegradability of 75-88 % CO2-generation was achieved in sewage treatment plant simulation tests, with a stepwise adaptation of the bacteria (constituting the activated sludge) to the necessary test concentration of 2,0 mg/l Triclosan. An environmental monitoring in real sewage treatment plants has neither found Triclosan nor possible metabolic intermediates (information of the supplier). Test data: - Sewage treatment plant simulation test with stepwise increase of the testconcentration from 0,04 up to 2,0 mg/l Triclosan: 75 – 88 % CO2generation. (Coupled Units Test – OECD 303 A and appendix to the regulation 88/302 EWG of 18.11.1987, published in the official gazette of the EU: L 133, 30.05.1988). The portion of the molecule that is converted and measured as chloride in the process of the analytical detection is determined as ”adsorbable organic halogen” (AOX). Depending on the national and regional laws in the EU and/or the application of the product, specific AOX – limits in the waste water may not be exceeded. The amount of AOX in this product is very low (0,4 %) and consequently the contribution of the product to the total amount of AOX in the waste water. 11.0 Auxiliary agents The product contains less than 0,2 % of different auxiliary agents e.g. preservatives. On account of the very low quantity, they do not represent a hazard to the environment. Ecological certificate of Skinsan Scrub Foam 9 esssf.doc State: June 00 _____________________________________________________________________________________________________ 12.0 pH-Value adjustment The pH-value adjustment of the disinfection working solution requires special evaluation. Strongly acid or strongly alkaline sewage can cause damage at the point of discharge into a channel system if it contains concrete as a channel material. Therefore, a pH range is prescribed for sewage discharge, mostly pH 6-10 (e. g. in Germany ATV Arbeitsblatt A 115). - The product has in a 1 %- solution a pH- value of 7 - Through discharge of the application solutions of this product, the sewage will not exceed the usual limiting values of pH 6 - 10. It con stitutes no danger to the channel system. (Dr. Harald Berger) Department of Ecology (Dr. Holger Biering) Department of Hospital Hygiene EDP-like conversion of the ecological expert report. The content is binding even if not signed and stamped.