By Neil Shifrin
July 18, 2013
Since the 1979 Love Canal hazardous waste site incident, we remain fearful and obsessed with cleaning and avoiding hazardous wastes. About $200 Billion will be spent on future Superfund responses. We pay dearly to address chemicals 50 feet below the ground, while we also pay daily to put some of those same chemicals under our sinks. Why the dichotomy? Partly, it is because we have no rational way to consider the risks from the products we use. We only consider the benefits - cleans well, costs less, leaves no residue. Perhaps we don’t consider the risks because we choose not to, or perhaps it is because no one has provided a system to help us consider them, although much information does exist.
Rating systems exist for other issues. For example, the U.S. Environmental Protection Agency has established the “Energy Star” system for appliances and gas mileage ratings for cars. All things being equal, we choose the 4-Star refrigerator over the 3-Star even if we don’t know what is really behind the rating system because we assume the system has merit. Perhaps a system could be developed to rate shampoos on the basis of health risk so that we could factor that in along with price and performance. Just as the Energy Star system has made refrigerators more energy efficient, overall, a chemical product safety rating system might make chemical products safer. Both consumers and manufacturers strive to be “green,” and a chemical product safety rating system could help both sides of the checkout counter be better at it.
Risks from Chemicals in Products
The European Union has enacted REACH (Regulation, Evaluation, Authorization, and Restriction of Chemicals) to help protect consumers from chemical risks. In the U.S., the Consumer Product Safety Commission enforces the 1972 Consumer Product Safety Act and other laws aimed primarily at physical dangers from products like unsafe cribs or cars, but the CPSC also aims at some chemical hazards. The EPA has many statutory authorities to consider chemical hazards, such as chemicals in drinking water, pesticides, and manufactured chemical hazard information under the 1976 Toxic Substances Control Act (TSCA), but the agency has no direct authority or consolidated program to consider chemical hazards from consumer products. The U.S. Food and Drug Administration (FDA) has some limited authority when consumer products intersect with food (e.g., food coloring) or for some personal care products, but once again, the FDA is probably not the right agency to deal with consumer chemical product safety on a broad scale. Besides, who wants more regulation? Let industry regulate itself on this topic. Consumers should demand it.
We are thus left with a regulatory framework that nibbles around the edges of the problem while we fall back on product liability litigation after the fact. Is the problem severe enough to do more, proactively? Consider the following, keeping in mind that whether a “toxic” hazard really exists depends on the actual exposure:
- Flame retardants offer obvious benefits, but can cause skin exposures to toxic chemicals.
- Cookware can emit toxic chemicals into kitchen air under some conditions.
- Plastic (e.g., food storage, beverage bottles, car seats, etc.) can contain toxic chemicals.
- Household cleaning fluids can contain the same chemicals found in Superfund sites at concentrations that would be a cause for million dollar remedies at such sites.
- Many building materials contain glues and chemicals that can be toxic.
- Personal care products contain hundreds of chemicals, some mysterious and proprietary (e.g., “builders”), which get rubbed into skin, onto hair, inhaled, and absorbed.
However, these examples only describe a potential for a problem from chemical products. As noted above, the actual existence of a problem will depend on the exposures. So below is a more precise example:
- A certain cleaning product is 50 percent degreasing solvent (by volume) with an inhalation safety threshold in air of 2 micrograms per cubic meter and a safe body burden level of 0.5 micrograms per kilogram of body weight (70 kg for a man) per day. It works great. (There is at least one such product actually on the market.)
- If 0.05 liter (a quarter cup) of that product is wiped onto a counter to clean it, and all of the solvent evaporates (a likely case), and the person cleaning inhales/absorbs one-tenth of what evaporated, that person has taken up 104,000 times the daily safe dose.
Similar calculations can be done for rubbing personal care products onto skin and for many other daily exposures to chemicals from products. There are many such daily exposures.
One way people currently deal with the potential for consumer product risk is to “go green.” However, this may be an overreaction (although we have no way of knowing) and it may be inadvisable, because there are plenty of “natural” chemicals that can also be harmful. We thus need a better understanding of two things: 1) is the problem significant enough (i.e., more studies like the example noted above are needed); and if so, 2) how do we organize the risk perception?
Rating System Possibilities
Most consumer product labeling requires explicit listing of only “active” ingredients with everything else grouped as “other ingredients.” Some of that “everything else” might be quite toxic. A review of cleaning products in the supermarket will reveal that most contain about 99 percent “other ingredients.” Worse, many products have nothing listed on their label except a Web address to inquire about ingredients (smart phones aside, this really hinders informed buying decisions). One can dig for the information, but how many of us have the specialized knowledge or the time to consolidate this information into a useful buying decision framework?
The simplest way to understand relative risks from chemical products is to rank their constituents by toxicity. That is essentially the approach of “Cradle to Cradle” authors William McDonough and Michael Braungart. There are two problems with this approach: 1) it may not be possible to remove all “toxic” chemicals from products (McDonough and Braungart would disagree), although we could certainly improve to some degree; and 2) the real issue is exposure, not toxicity. Even water is toxic in sufficient quantities.
An improved rating system would consider both toxicity and exposure, but as potentials within expected uses of the product. Toxicity is already expressed as a potential, but exposure characterizations from product use would need a more practical expression. Otherwise individual risk assessments would be required for every exposure of every chemical in every product, which would quickly bog down any rating system. A simple example might be a high rating (safe) for a product with few inherently toxic constituents, glycerin skin lotion for example, and/or with little potential for exposure, such as footpad gel.
A successful chemical product rating system would be simple, transparent, and offered by a trusted source. Chemical product safety is an important factor, but it is only one of several factors in consumer buying decisions, so the rating must be intuitive and obvious. With such a system, manufacturers could improve products more rationally, use good ratings as a marketing tool, and consumers might be better protected while feeling more informed. Our daily chemical exposure from products is likely to be much higher than from any form of pollution.
Dr. Shifrin is an environmental engineer and a director in Berkeley Research Group’s Waltham, Mass., office. He has worked on essentially every kind of pollution issue for 42 years and specializes in chemical exposures. Shifrin can be reached at [email protected].