Green Chemistry and Design for Sustainability Because everything is chemical but heat and light PTA

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Design for the Environment Green Formulation
Initiative Update and Opportunities for NSF
NSF Steering Committee Meeting October 25, 2005

Richard Cottrell Manager, Non-Food Regulatory /
Technical Services SYSCO Corporation
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Overview

• Drivers for green product designation and
  recognition
• DfE Green Formulation Initiative and the
  CleanGredients database
• Potential Opportunities for NSF International

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Purpose of the DfE GFI

• Develop a one-stop database of Industrial
  Institutional (II) cleaning ingredients and
  their characteristics to
• help formulators identify ingredients that may be
  useful for green product formulations
• provide opportunity for manufacturers and
  producers of cleaning ingredients to showcase
  their ingredients with environmental and/or human
  health and safety attributes.
• Our intention is to promote the development and
  marketing of innovative, green chemical solutions
  in the II cleaning product industry and to
  facilitate informed choice.
• We intend to make the resource accessible to
  formulators at no cost and to suppliers at low to
  no cost.
• By characteristics we mean functional
  properties such as critical micelle
  concentration, physical properties such as log
  Kow and associated environmental and health
  toxicological information.

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Drivers for Green Chemistry in II Janitorial
Cleaning Products

• Executive Order 13101, Greening the Government
  through Waste Prevention, Recycling and Federal
  Acquisition
• Other city, state and private sector purchasing
  initiatives
• U.S. Green Building Council LEED - Existing
  Building Program
• Eco-labels e.g., Green Seal, Environmental
  Choice, etc.
• U.S. EPA Design for the Environment Formulator
  Program (www.epa.gov/dfe/projects/formulat/index.h
  tm)
• Current availability of effective alternative
  surfactants and other ingredients (ie chelators,
  builders, etc.)

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Obstacles to Integrating Green Chemistry into
Product Formulation

• Comfort with status quo
• Defining what is green
• Manufacturer market challenges customer
  disconnect
• We can make anything, but customers are not
  asking
• We make green chemistries but customers are not
  buying
• Missing human and environmental toxicological and
  life cycle impact data to support decision making
• Material Safety Data Sheets
• Technical Fact Sheets
• Data are available but dispersed

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Collaborative Agreement with EPAs Design for the
Environment Program

• EPA as active partner data review, overlay
  definition
• DfE Formulator Program
• Voluntary program whereby EPA Reviews and
  profiles all ingredients in formulations
  submitted by manufacturers
• Situates chemicals on continuum of improvement
• Recommends substitutes or reformulation
• Successful reformulation results in EPA
  Partnership and use of the DfE logo on product

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1 DfE Formulator Program Question

• Is there a list of safer chemicals we can use in
  making our ingredient choices?

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Technical Advisory Committee
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The Big Conceptual Shift

• After
• You tell us what information you need on which
  attributes in order to make choices in
  formulating products with environmental
  attributes
• We work with suppliers, EPA and other partners to
  provide data and benchmarking against useful
  cut-offs (eco-label, Globally Harmonized System
  of Hazard ID, U.S. EPA DfE Program)
• Formulators can develop their own Green Lists

• Before
• We identify green ingredients through
• Ranking
• Lists

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Approach

• Start with surfactants to establish
• Process for identifying attributes, criteria and
  cutoffs
• Request for Comments solicited from Project
  Associates
• Work with Technical Advisory Committee
• Data needs
• Database functionality and web interface design
• Protocols for data and ingredient information
  collection
• Move to next ingredient class
• Solvents and builders proposed
• Steering Committee will decide

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Ranking

• Database should not rank ingredients but rather
  provide data with overlays of standards, hazard
  criteria, or other independently established
  requirements to help formulators i.e.
• Criteria for hazard identification from the
  Globally Harmonized System (GHS)
• EPA DfE criteria for partnership
• Eco-labels such as Green Seal (US) or Ecologo
  (Canada) requirements
• EU Detergent Directive requirements

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Proposed Ingredient Submission Process

• Supplier registers to list ingredient. Fees have
  not been determined. Goal is to keep costs low.
• Supplier enters all ingredient information to
  database via online submission form
• Supplier separately submits formulation (full
  disclosure) to U.S. EPA DfE Program along with
  data for aquatic toxicity and biodegradability
  for review, screening and verification
  ingredient is considered under review. Once
  reviewed, it is reviewed.
• Ingredient information in database is a
  combination of reviewed and not-reviewed
  information

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Recommended Human and Environmental Health
Attributes

• Tier 1 Test data and 3rd party review required
• Aquatic toxicity (at least one endpoint required,
  modeling may be accepted to supplement test data)
  
• Biodegradability (required on ingredient/preparat
  ion accepted for individual components also)
• Tier 2 Required if known, self-reported
• Sensitization
• Acute mammalian toxicity
• VOC content
• Degradation by-products
• Presence of APEs
• Irritancy
• Tier 3 Optional but environmentally relevant,
  self reported
• Other Product Features (i.e., biobased,
  bioderived, cold water functionality, etc.)
• Life cycle assessments
• Risk assessments

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Other Human and Environmental Health Attributes

• Attributes to be excluded for surfactants
• Performance properties (in the sense of quality
  of performance)
• Endocrine disruption
• Biobased
• Bioaccumulation potential
• Neurotoxicity
• Not discussed
• Other (list-based concerns) e.g., carcinogens,
  mutagens and reproductive toxics (CMR),
  regulatory and policy concerns (i.e., banned,
  regulated in EU, Canada, US)

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Levels of Information

• Database provides for initial screening followed
  by deeper dive into ingredient information
• Test results
• MSDS, Technical Fact Sheets
• Other supporting documentation
• Contact information, etc.

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We Hope this Project Will

• Help Inform a Larger Audience
• Provide a Showcase for Chemical Ingredients with
  environmental benefits (Green Chemistry)
• Provide a fact-based source of environmental fate
  and toxicity information on potential cleaning
  product ingredients
• Allow formulators a one-stop opportunity to
  select ingredients that will enhance the
  environmental fate and safety of their formulas
• Provide a resource for ingredient producers to
  communicate the environmental fate and safety of
  ingredients in a standardized input format for
  current and future ingredients
• Promote an ethic of continuous improvement
• Leverage U.S. EPA Formulator Program services.
  Streamline Partnership by having information on
  ingredients already reviewed and publicly
  available.

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Potential Opportunities for NSF International

• Important parallels between lubricant
  registration program and criteria review process
  for ingredients submitted to CleanGredients
• EPA is not interested in long-term commitment to
  ingredient review (neither is GreenBlue)
• Database provides information on
• Whether or not an ingredient meets the DfE
  criteria
• Data itself within a well-defined reporting
  structure

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