It Was All Trees and No Forest

The EPA's DfE (Design for the Environment) Earth Week announcements and final material standards for 2500 chemicals have been published. Not specifically mentioned is the additional 2500 plus fragrance ingredients that were assessed for human and environmental safety. Why? Because Fragrances will remain being the label identity.

The contextual issue of Trade Secrets was carefully resolved in cooperative comment process. Going forward the DfE partnerships are now an emergent system of simultaneous top down and bottom-up relationships. Goals and objectives will be motivated by mutual respect, trust, product performance and innovation. Bottom-up the formulators will be working with Perfumers that have the tools for responsible products. Top down, the central protectionist concern for Fragrance houses and self-regulated trade associations, Trade Secrets, are preserved but with new terms.

It is within these terms that lie boundless opportunities for strong profits and environmentally recognizable achievements.

Toxicology, Peer Review and Singularity

Toxicology has long left the bench and its vapor pots to develop new skills unique to product safety questions and environmental impact discoveries. Very often the environmental concerns for cleaners had never been thought about prior to the 1970's Clean Water Act. Dilution was the learned response. Now, because of the advances in chemical analysis, the need for hazard risk assessments and green standards were raised.

So how does "peer review" expedite the concerns of society for public safety and the maintenance of environmental health when modeling programs provide more powerful and profound predictive analysis? A mere technological singularity, if we dare say.

"But sheer processing power is not a pixie dust that magically solves all your problems" (Steven Pinker 2008). So we wait and wait for a peer review which is always irrelevant when the net result is the same regarding aquatic toxicity.

Let's quickly move on and reduce toxicity in our waterways.

Moasting

Next week IFRA is conducting its Annual Business Meeting. Featured will be a speaker from the Competitive Enterprise Institute who will outline the "precautionary principle approach" for global environmental and safety regulations.

I encourage members to study at least the "soft" approach prior to the presentation. It's a worthwhile topic that deserves a deeper understanding beyond the elementary stance to demean other sciences as a defense for a chemical of concern - woof woof!!

Will IFRA management finally not identify Environmental Scientists as modern Plague Doctors causing more harm then good? Or will IFRA members and product formulators see the final resolution is disclosure of ingredients, not fragrance compound formulas.

One simple demonstration is this blog will start listing workhorse aromatics used in fragrances [the standard label practice] contained in cleaning products that are rinsed down the drain. The materials have proven formula value for cost in use, general stability and performance. These items were screened for human and environmental safety criteria. However, compounds that want DfE certification will need third party review as required for sponsored products. A positive list, that should be available in the clouds, will simplify the issues and all can finally move on.

Please note, I have chosen to use the common industry identity for clarity. The CAS number will identify the chemical name. Like any "list", regulators may choose to delist or announce a review. IFRA and their members are very familiar with that process.

ALDEHYDE C-8 124-13-0
ALDEHYDE C-9 124-19-6
ALDEHYDE C-10 112-31-2
ALDEHYDE C-11 UNDECYLENIC 143-14-6
ALDEHYDE C-12 LAURIC 112-54-9
ALDEHYDE C-12 MNA 110-41-8
ALDEHYDE C-14 104-67-6
ALDEHYDE C-18 104-61-0
ALLYL AMYL GLYCOLATE 67634-00-8
ALLYL CAPROATE 123-68-2
ALLYL CYCLOHEXYL PROPIONATE 2705-87-5
AMYL ACETATE 628-63-7
AMYL BUTYRATE 540-18-1
AMYL SALICYLATE 2050-08-0
ANETHOLE 104-46-1
ANISIC ALDEHYDE 123-11-5
BENZYL ACETATE 140-11-4
BENZYL SALICYLATE 118-58-1
BORNEOL L 464-45-9
CAMPHOR POWDER 76-22-2
CITRONELLAL 106-23-0
CITRONELLYL NITRILE 51566-62-2
COURMARIN 91-64-5
CYCLACET 5413-60-5
CYCLOPROP 17511-60-3
DAMASCONE DELTA 57378-68-4
DIHYDROMYRCENOL 18479-58-8
DIMETHYL BENZYL CARBINYL ACETATE 151-05-3
DIMETHYL OCTANOL 151-19-9
DIMETOL 13254-34-7
DIPHENYL METHANE 101-81-5
DIPHENYL OXIDE 101-84-8
ESTRAGOLE 140-67-0
ETHYL AMYL KETONE 106-68-3
ETHYL VANILLIN 121-32-4
ETHYLENE BRASSYLATE 105-95-3
EUCALYPTOL 470-82-6
HEDIONE 24851-98-7
HELIOTROPINE 120-57-0
HEXENOL cis3 928-96-1
HEXENYL ACETATE cis3 3681-71-8
HEXYL ACETATE 142-92-7
HEXYL SALICYLATE 6259-76-3
IONONE ALPHA 8013-90-9
IONONE BETA 79-77-6
ISO BORNYL ACETATE 125-12-2
KOAVONE 81786-73-4
LILIAL 80-54-6
LINALYL ACETATE 115-95-7
MANZANATE 39255-32-8
MELONAL 106-72-9
METHYL ANTHRANILATE 134-20-3
METHYL BENZOATE 93-58-3
METHYL CINNAMATE 103-26-4
METHYL NAPHTHYL KETONE 941-98-0
METHYL OCTYL ACETALDEHYDE 19009-56-4
METHYL P-CRESOL 104-93-8
NEOFOLIONE 111-79-5
NEROLIN CRYSTALS 93-04-9
PHENOXY ETHYL ISO BUTYRATE 103-60-6
PHENYL ETHYL ACETATE 103-45-7
PINENE ALPHA 80-56-8
PINENE BETA 127-91-3
ROSE OXIDE 16409-43-1
STYRALYL ACETATE 93-92-5
TERPINEOL ALPHA 98-55-5
TERPINEOL 200 98-55-5
TERPINOLENE 90 586-62-9
TERPINYL ACETATE 80-26-2
TETRAHYDROLINALOOL 78-69-3
TETRAHYDRO MUGUOL 18479-57-7
TRIPLAL 68039-49-6
UNDECAVERTOL 81782-77-6
VANILLAN 121-33-5
VERTENEX 32210-23-4
VIRIDINE 101-48-4