The Move Toward Ingredient Disclosure

By Stephen Ashkin


Schools and universities have been true leaders and early adopters of Green Cleaning.  Combined purchasing power has resulted in hundreds of manufacturers who now offer “green” certified chemical and other cleaning products, and the total number of certified products is now in the thousands.

Today an emerging strategy to get beyond the basic certifications is to buy from manufacturers who provide complete “ingredient disclosure.”  Purchasers believe that the additional ingredient information will help them identify products that might better meet a specific need such as protecting small children, pregnant woman or building occupants with specific health conditions such as asthma.  Furthermore, they believe that if manufacturers divulge complete information they will use more care when selecting ingredients as they won’t be able to hide problematic ones by simply keeping them under legal reporting requirements.

Currently the requirement for reporting ingredients is based on the Occupational Health and Safety Administration’s (OSHA) Hazard Communications Standard which created the Material Safety Data Sheet (MSDS).  The MSDS only requires the disclosure of hazardous ingredients in the formula above one percent and carcinogens above one-tenth of one percent.  But there was no requirement to disclose hazardous ingredients below the minimum thresholds, nor to disclose any ingredient not considered hazardous.

And while some states such as New Jersey required that the top five ingredients by amount be listed on the MSDS, most states do not require this.  Thus for many chemical cleaning products the MSDS actually provide purchasers with little insight into the ingredients in the product being used.  And the MSDS provides little insight into a product’s impacts on the environment as it is solely focused on protecting worker’s health and safety.

While the MSDS was a good start, full ingredient disclosure will create voluntary incentives which will help reduce the health and environmental impacts of the products and reward innovative manufacturers who go beyond the minimum requirements of the MSDS and the third-party green certifications.

The reason ingredient disclosure is now taking hold is that an approach has been developed which meets the needs of these purchasers and others such as children’s health and environmental advocates, and is protective manufacturers who need to protect legitimate confidential business information (trade secrets).

This new approach was led by the Consumer Products Specialties Association (CSPA) which is a major chemical industry trade association and the Sierra Club’s Toxics Committee which is one of the oldest and largest environmental organizations in the US.  Their approach lays the foundation for an ingredient communication program that will be adopted by manufacturers and purchasers, as well as third-party certifiers such as EPA’s Design for the Environment Program (DfE).  Ultimately this approach will likely be the foundation for federal legislation on this subject due to its broad support.

Ingredient disclosure is easy for purchasers in schools and universities to use.  All that has to be done is to look on the label of the chemical products to see if it includes the following:

  • Disclosure of all intentionally added ingredients
  • Ingredients must be disclosed on the product label, on the formulator’s Web site, at a toll-free number, or on other media
  • List highest percentage of concentrations in descending order

Clearly the issue of ingredient disclosure is on the horizon and it really can make a difference in efforts to further protect health and the environment.  If current cleaning chemicals do not provide full ingredients disclosure, discuss it with the supplier as they may represent a manufacturer which does.  Schools and universities can demonstrate leadership by simply buying from these innovative manufacturers and the cost of this improvement is ZERO!

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