Nose Against the Glass

As we all have been waiting the past few weeks for the Bush administration to relax existing requirements in order to deregulate and weaken environmental protections along comes a National Academy of Science's report commissioned by the EPA. The report was made public on 12/3 at www.nas.edu. 

According to the NY Times 12/4 article, the report highlights how certain EPA regulatory assumptions identify information gaps as defaults and therefore treat a suspected material as no risk. In the specific case of Fragrance materials which are always used in very complex combinations, I have to wonder how the pending DfE (Design for the Environment) material review module which is expected to be running by year end, will ever pass EPA Management's final  review. 

The external DfE module which has been in development for over a year and is a positive process step to develop fragrances for institutional and consumer products that are rinsed off down the drain. Fragrance industry self regulating agencies were involved in the standards phase and managed to finally drop their self preservation stances in the light of intense political and economic pressure. Now we have to worry about the final days of the Bush administrations low regard for environment regulation and not forgotten, Child Safety or Worker Safety programs?

My Green nose is against the glass.    

Green Aspiration

Most fragrance trends are created by the perfumer skillfully adding a new nuance or "note" to an existing theme. The time honored example is Coco Chanel mistakenly adding too much Aldehydes to her floral creation. This provided a sophistication and an attractive uniqueness. This mistake became Chanel #5. As people encoded this odor memory as they were exposed to the #5 Perfume form or the hundreds of adaptations that followed in skin products, a trend was born and tracked. 

This "conditioning" of recognizing new fragrances and inputting borrowed demand has repeated itself in nearly every fragranced product. Even when something was technically deemed impossible like chlorine based cleaners, R&D was devoted and rewarded with positive results.

Today consumers are so manipulated that they have created a real economy based on products that they adorn themselves, their clothing, living space and everyday cleaners with every evolving trends. Most of this actually serves a common good and should thrive. People are healthy, feel better about themselves and how they want others to relate to them. Houses are cleaner and germ free as the fragrance products promote correct usage and hygienic habits. And despite the so-called synthetic chemical backlash, what people put on themselves is a free choice and causes virtually no harm. 

Now the tasks are to inform people that there is a small population sector that has a real sensitization and we should all try to minimize contact when known. And we should all voice opinion and try to influence consumers that they do not need fragranced cleaners that imitate every odor trend when the raw materials, both of Natural and Synthetic origins are tested for its environmental impact. We can actually start this in 2009 when the EPA DfE (design for the environment) program provides the Perfumers a method to access raw material data for environmental persistence, sensitization, carcinogenicity, reproductive toxicity and target organ toxicity. Thereafter, the consumer can intelligently decide and aspire to make their space a healthier place while contributing to a safer planet.  

 

Rocket Scientist

Referring back to the GCI article on "Materials: Scent of a Winner" September 2008, I could not help noticing the claim, that was recently repeated by a RIFM representative, that material bans often seem to have no basis in valid scientific research.   An example was given in the GCI article, that some ingredients in fragrance formulations are used in very small concentrations, "say, one part in a billion, which in scientific terms means  "VIRTUALLY UNDETECTABLE."  In terms for those without scientific backgrounds, that's the equivalent of one inch in 15,782 miles.  But if legislators see a given ingredient as a risk, a valuable ingredient that has served the industry safely and effectively for years may be lost.  This hurts perfumery."

Lets assume since the article was in a trade journal, that the readers have some scientific background and understand or appreciate why the example was given.  And that the readers know that the practice and prior safe use of a perfumery material does not likely include an environmental test standard such as water or soil phase toxicity as these are currently being assembled.  

Tests like, Level 1 Fugacity are used to determine the relative concentrations of a chemical in water or soil phases at equilibrium.  And since all perfumery items have different tendencies of "fleeing" or accumulating, it is scientifically impossible to relate ingredient dosage to dilution miles.  

The Green Nose just wants to remind the Fragrance industry that the use of many longstanding materials is based on attractiveness, skin safety and performance.  Performance by evaluation techniques is most liked by consumer panels when the ingredient's effect is long lasting and has awareness.  Environmental behavior is a new standard and now a product registration requirement.  Therefore the inadvertent use of materials that are recognized as an environmental hazard can not be excused away today.  Success is judged by the absence of aromatic ingredients in the waste stream. 

In non-scientific terms, you do not have to be a rocket scientist to understand that compounds for example, that were designed for fabric fixation and to survive a cold or warm washing and drying cycle and last for weeks in storage, will accumulate in water and soil in our population centers.   They were scientifically designed to not flee.

    

          

Green Economy Awareness and 401K losses

When the global credit bailout steps are finally set in place, and after your 401K / IRA statements are digested, we all should be AWARE to focus on personal health and thriving as the first important process step to recovery.  And  good personal health includes a healthful environment. 

 

If we Green the bailout, it is possible to create more economic value and purpose to our everyday survival.  Imagine a rescued new economy that includes real and safe science, materials, and manufacturing.  Or should we continue with a dread and reluctance to Greening our consumer and institutional product world only because of the ordeals of change and risk?

The Green Nose's objective today is to encourage our global economic makeover to include specific goals, timeline and incentives that all products that go down the drain do not linger, contaminate or poison our water.    It is doable, viable and not a wistful whim.         

   

The Green Monster

Kudos to Mike Napoli of the CA Angels to hit two homers out of Fenway last night.  Two other green monster homers were quietly signed into law this week, A.B.1879 and S.B.509 that will give CA state regulators to identify, evaluate and have the authority to ban potentially industrial chemicals of concern.  Both bills establish the framework for a comprehensive Green Chemistry program to reduce or eliminate toxic substances in consumer products and the environment.  A.B.1879 gives the CA Dept. of Toxic Substances Control till January 1, 2011 to develop a science-based program to identify and prioritize chemicals of concern and analyze alternatives or improvements through the establishment of an advisory Green Ribbon Science Panel.  

The companion bill S.B.509 requires establishment of an online Toxics Information Clearinghouse to increase consumer knowledge about the toxicity and hazards of everyday chemicals.  It also requires the Office of Environmental Health Hazard Assessment to develop, through a public process hazard traits and environmental and toxicological endpoints for the online clearinghouse.

Very heady events but not without warning.  For the past couple of years, EPA's DfE program has opened their data channels from the committee work that has been coordinated with CleanGredients.  One of the data sharing outlets has been to the CA EPA.  The first three studies involved the establishment of attributes and criteria for surfactants, then solvents and recently Fragrances.  I happened to participate in twenty sessions for the Fragrance TAC, and a working module  for Fragrance industry members should be operational by year end if EPA management gives clearance.  More specifics can be gleaned from the DfE website and www.greenblue.org.   

The "green monster" for the fragrance group was protecting trade secrets and manage to identify as many as possible allowable ingredients for DfE clearance.  The system still in place, is for sponsor companies to submit their entire formulas for safety review.  The Fragrance formulas would be submitted and opened for third party review (mostly to www.nsf.org) directly by the fragrance creator/supplier by-passing the manufacturer.  Some of the larger consumer companies already have an open formula procedure for their own product safety guidelines and vendor contract requirements.  

One green monster element was that nearly all fragrance formulas after review have needed some revision.  Since the sponsor's product had already been tested for fragrance stability and odor purchase preference studies, most products were launched with a provisional approval though all the consumer saw was the DfE logo.  Why, how come, what was needed, who would find a workable first level fragrance formula solution?  We'll address this in future posts.

The epizootic green monster for Fragrance self regulatory associations is now keeping peer control over scientific studies, not interrupt the supply chain despite numerous data gaps, make members aware of safety positions and develop strategy for a new science, environmental toxicity that now has equal standing.  In effect for this blogger, after I worked through the process issues to satisfy my customer's needs, I was confronted that I should share my data and join the same regulatory organization that does not want independent member solutions.  Furthermore, environmental science was chided in speeches or private letters as only a "social science", "Internet science" and a potential cause for consumer group's criticism.   Basically, I was told bottom line, there would be too much negative attention and need to revise fragrances currently in the marketplace.  

Ouch.  More to follow.  

   

Green Chemistry and current Fragrance Industry position

I was not going to start out this way. Too many excellent references I'd prefer to first mention such as Maria Cone's two articles in the LA Times (Environment) as well Thomas Friedman's promotion of "The Green Collar Economy." But the recent article in GCI titled Materials: The Scent of a Winner is purposely obfuscating the challenges of Green Fragrance's for cleaning products.

I like the piece with regards to the industry's history for safety, on-going research, creativity, green marketing and intellectual protection. However, it's overall premise only applies to toiletries and personal skin care items and not to products containing fragrances that are rinsed off down a drain.

Firstly, the industry association, FMA that the GCI article's author is a board member, is not a cheerful participant in the ongoing regulatory reviews of EPA's DfE (Design for the Environment) and EU's REACH. The FMA has valid scientific concerns that many commonly used fragrance materials will not meet the soon to be finalized environmental safety standards resulting in the palette reduction the author fears. Furthermore, he is sticking with an invalid environmental risk assessment based on dosage and quantitative analysis rather then hazard based analysis. Quantitative risk analysis is regarded as acceptable for human safety toxicity but not for peer reviewed attributes and criteria for environmental toxicity. Hazard based analysis or modeling reflects the concentration of bio-accumulation in the population centers. Hazard risk modeling is closer to reality.

Secondly, there is more then enough fragrance raw materials that will pass human and environmental toxicity review to create attractive clean smelling functionally acceptable fragrance compounds. Will these compounds smell similar to the latest or classic cologne, candle or after bath splash? Not very. Because the overuse of persistent trendy long lasting materials found in those unique creations are the source of bio-accumulative and aquatic toxic material discoveries in sediment and estuaries.

Thirdly, looking for clarity in the overuse of green marketing does not exist in the overall cleaning industry initiatives sponsored by the DfE. The personal skin care platforms, most often associated with natural, organic, essential oils, are borrowed terms from food product trends. The food industry has struggled with authenticating the organic origins and material processing. Whereas the long established fragrance industry practice is to utilize standardized odor qualities that are readily available with tiered purity and cost for the intended end-use. Most of the so called naturals in use today in cleaners are technical grades that contain many impurities. Only recently have suppliers offered traceable certified organic fragrance materials but their availability is limited and costly to find usage in mass produced products.

Lastly, what really is compelling is the foot dragging (again see the LA Times article) and the fear that many fragrance compounds need to be revised and that the fragrance industry will suffer a negative image and the resultant slippery slope will carry over into all product categories. The FMA is protecting the supply chain as their primary interest.

So, my message is we can create customized attractive fragrance compounds today and continue with providing fragrance products market uniqueness and pleasure. A transition to a greener future is already within our grasp. Consumers and professional cleaner manufacturers will embrace this transition. Value does exist in the economy for Green Chemistry. We do have ahead some meaningful assignments to revise persistent bio-accumulative and aquatic toxic formulas but better to be GREEN before it's too late.