Monday, October 6, 2008

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   

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 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.  


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