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

Inception

Last week the US/ EPA celebrated its 40th anniversary and honored the many accomplishments of their staff to identify and improve human and environmental conditions. Please read the remarks by Administrator Lisa Jackson, who has strongly lead the essential direction of this front line government agency for the past two years.

Very noteworthy to this blogger is last month's release for comment, the proposed fragrance ingredient enhancements to the DfE (Design for the Environment). This report was prepared by the EPA in consultation with Fragrance material toxicologists, trade associations, cleaning industry formulators, fragrance industry product development and marketing representatives. Equally important was the sponsorship and organizational guidance from GreenBlue and CleanProduction.

The process of developing and/ or organizing attributes and criteria for human and environmental safety guidelines fell to a group called the Fragrance TAC Team. Wisely the TAC did not cover air fresheners (allergens) or personal care liquid soaps and shampoos. The focus was on standards for institutional and consumer product cleaners, the largest volume of product usage for worker and consumer safety. It still took nearly four years for the proposal to be submitted.

Several scientific norms and task behaviors needed to be addressed before the TAC was comfortable to be forthcoming in the twenty plus telephone conferences and side meetings. One reason, most members of the Team were involved in the "tox" reviews of the fragrance formulas. Almost all submissions for sponsored formulators were rejected and assigned to a pending status. These TAC members were confused what exactly to do and instruct their Perfumers. They all looked to work with detailed guidance from RIFM/ IFRA the leading trade association. Membership requires strict adherence to RIFM guidelines. ["Anyone who conducts an argument by appealing to authority is not using his intelligence; he is just using his memory", Leonardo de Vinci (1452-1519)]

A second reason, RIFM's extensive fragrance material data is based on QRA (quantitative risk assessment), with no effective link to a Hazard based approach vital to environmental modeling for population centers. After several failed strategy attempts to "shrink environmental science" as not equal, the top toxicologists and trade associations relented because they had no environmental data for the workhorse fragrance materials used in cleaners. Essentially in the last decade, they underachieved their own profession, trade members and employers. Worse they had no authority to quit the TAC.

The lead industry scientists did rally beyond their negociant procedures and assembled new criteria for essential oils, a material that will need closer examination because of a lack of quality standards between perfume and technical grades. Going forward, instead of merging DfE data from RIFM members, a consortium was formed. Their first task is to hire a consultant (budget $150,000) as the popular complaint is the proposal document is too complex. Or is this retort still a rivalry of aims? Certainly the work of the consortium will be time consuming and cause an undetermined delay. Ummm.

One Who Serially Sits on Committees

After five years of planning, organizing and numerous meetings, the DfE program now has the fragrance ingredient criteria to execute a more effective program with stakeholders. Why the five year struggle? How unique is a fragrance formula? What is the effect of transparency? What really matters?

What matters is SAFETY for consumers, workers, children, pets, and the environment.

The committee members of the Fragrance Technical Group do deserve credit for their time and transformation. As a member myself I want to think that everyone involved will show support and do the tasks ahead. We don't need more discussion or definitions, just action.

Moral Hazards

Does belonging to IFRA under today's regulatory climate constitute a moral hazard? This is a question that was tossed at me recently. Another question and statement was how Fragrance industry regulators are only interested in expanding their numbers, influence and dragging out "comment periods."

In a recent article observing that the moral hazard with self regulatory groups, "Leniency in Private Regulatory Enforcement: the Role of Organizational Scope & Governance." is greatest when enforcement includes products that entice customer loyalty.

The article proposes that internal regulatory enforcement is higher rather then at a self regulatory agency because there is no consequence to the independant regulators.

IFRA members please resign and demonstrate to your clients a higher enforcement standard.

RESIGN IFRA

Science has it's rhythms.

These rhythms are often beautiful to observe and listen. Right now environmental science is stroking the rhythm of safe cleaning products in consumer and workers hands. How and why? Mostly from sound and steady intellectual improvements, organization and openness. Essentially environmental scientist called for precautionary principles rather then bans.

Now that the DfE standards for safe cleaning product ingredients are established, it is time to step back and take account the main players in the process, in particular the last four years when the attributes and criteria were organized.

My call to arms is Fragrance Houses resign from IFRA. Let the industry "core company" board members run it, pay for it and audit themselves. The principle material data is available and future changes must be published. There is no obligation that any of you must don the IFRA RIFM FMA hair shirts.

Go out and do what you do best. Innovate. Make great colognes, skin products, again. Follow the rhythms of the crowd, trend setters or savants. Devote your resources to creativity and safe practices. It's about customer requirements.

But when it comes to rinse-off products, don't be evil. Relax on trying to delight consumer test panels and overwhelm our senses by trickle downing every innovation and condition the masses. Be transparent, disclose your inventory and you will not have to open your formulas. Ever.

IFRA: NAVEL GAZING

It's often been stated by scientists that the weakest science is medical studies. Their conclusions are based on small surveys, numerous measurement errors and the tendency to discard data that does not fit. Ultimately, that is why health issues represented by self-regulated industry associations are most times wrong.

The trouble with wrong positions is, they are justified by an institutional imperative of mindlessly imitating peers, no matter how foolish. This imperative is so deeply supported, entrenched and enforced, often the wiser choice must wait till the leadership changes.

Some examples; whenever a specific material's safety in use is challenged, IFRA's first reaction is to divert attention to the entire body of work. Yet every chemical examined (+3000) has a different back story __ why, how, when and who supported the cost.

-Ingredient transparency is not a threat to formula disclosure.

-Toxicology studies sponsored by NGO's are not evil. Their intent is universal, like worker, child and water safety.

-Environmental data gaps are not justified. "Spray and pray" is how grandfather did it.

-The non-disclosure/ transparency terms for the proposed "open to all" consortium for assembling DfE criteria will
stall conversion to safer compounds.

The biggest threat to "business as usual" comes from the EU REACH program. But the response from the IFRA Board and guardians has only increased cost and risk to all segments served. As I have stated before the industry should have focused on revising fragrance compounds in products that are rinsed off. That solution is still in hand.

One sure action, Business Managers, stop approving expenditures for outside consultants. Your own regulatory staff have been lazy, self-absorbed, wasting time and money while taking IFRA's lead...... navel gazing.

NOSE CANDY part 2

The recent publication about disclosure of unsafe fragrance materials found in an analysis of leading consumer products has had a response from FMA aka IFRA North America. The complete response can be found on FMA's website under two sections, "Fragrance Safety is No Secret (5/12/10)" and "FMA Finds New Cosmetics Report Misleading (5/13/10)."

The Green Nose finds these statements to be the most responsible, open and carefully considered comments by IFRA. Bravo for coming out of the gates swinging.

But before IFRA and the FMA's organization arm, The Robert's Group, get too crafty, haughty and confident in their lobbying efforts, peer review is not always relative to argue about and opens yourself to similar claims. For example, The publication of IFRA's fragrance tested material list makes no claim to its completeness with it's member companies. Nor did the release have any disclaimer or statement about new chemicals, revised processes or proprietary materials that have not been peer reviewed.

The Green Nose does give extra weight to environmental toxicity since I want to equalize the human and environmental safety concerns. I wrote before how a former employer accidentally caused a DEP spill and it entered a stream resulting in a noticeable fish kill. The amount of DEP was very small as it came from empty drums that were left outside without their bungs (root cause). Some quanity of rainwater accumulated in a weeks time and the drums were drained in our plant yard by the drum recycler. I can't relate this tale to FMA's dosage statement about a grain of sugar in an olympic swiming pool but what I do know is the minuscule amount was detectable to the water commission's GLC and their claim that DEP is an oxygen depleter. Should we have insisted on a group of scientist to review the findings when the state Water Commission shut us down?

NOSE CANDY part 1

With Earth Day approaching there are some things to be thankful for.

The official announcement for the merger of RIFM and FMA into IFRA.. This reorganization of resources may give a greater promise to a greener result for fragrance materials. This should signify the end of the protectionist stances and a shift to the innovationist. I am hopeful that this will forward transparency into the supple chain, and provide identity to aromatic materials that pass EPA's DfE review for human and environmental safety.

The completion of the Fragrance Technical Action after nearly three years. The how, what and when of the DfE program will have a seperate session at the second Sustainable Fragrance conference in May.

Procter & Gamble, who directly creates, compounds and markets Fragrances that would rank them in the top three companies has started a sustainability expert panel. This may compensate for P&G not becoming one of the primary member firms in the new IFRA structure. This glaring ommission maybe due to an arcane by-law of RIFM membership, if so that should be changed. P&G are today the only major "soaper" who creates their own compounds and largely responsible for the polycyclic musk environmental contamination.

THE HISTORY OF BEAUTY by Geoffrey Jones is published. This respected business study brings positive attention to the industry I love.

Keeping the Dream: IFRA Preposes RIFM and FMA

Buy the dream and you will live forever. Betray its legacy and you will wither. Ignore your detractors and you will perish.

Protect your golden icons, drive cost from your business, promote, generate repeat sales against competitors, innovate, be transparent about what matters, and always look forward expressed in new products. Easy.

So what happened that a regulatory monopoly is now necessary? Is it just conceptional enemies or a self regulatory mobilization demanding relevance?

Lets look at the legacy and the internal and external markets that are served.

ELITES - This is the bonafide, artistic, critically acclaimed trend leaders whose work is expressed through limited, exclusive distribution. Master perfumers status and reputations are made using what nature, science and imagination can provide.

PREFERRED - These are avatars of the Elites, using more science and precision. Preferred products are intended to aspire, feed the frenzy, promote ubiquitous images/ memory and drive traffic to the dream. Supply is determined by privilege, give backs and performance.

OUTSIDERS - This is populated by technicians who satisfy real every day needs. Their art comes from existing available material sources, natural and synthetic, mid grade to technical qualities. Their products thrive in public health usages.

How will IFRA be effective serving these interests? Will they preserve the materials the Elites demand? Will IFRA's primary focus be on the EU Regulatory process and assign fiscal responsibilities in the global supply chain for the Preferred? IFRA already assumed January 1st the fragrance related regulatory functions and advisory initiatives of the European Flavour and Fragrance Association. Will IFRA personalize the transparency process for environmental science? Can IFRA inspire trust and leadership when prior self regulation tactics fostered a squeamishly incoherent anti-fragrance movement?

What is evident on the regulatory agenda are of course, educational forums. FMA just hosted a speech from Stats.org. RIFM will address this week how "Transparent Science Supports Brand Trust." And IFRA is grappling with population risk hazards vs quantitative assessments.

Upcoming in May will be a seminar hosted by EPA's DfE, and third party reviewers NSF, and ToxServices to guide Fragrance creators through the new DfE screen. This precedes the Sustainable Fragrances 2010 conference, which should be more progressive then 2009's program. Since the DfE screen should include environmental safety hazards, seminar attendance is critical, affordable and inexcusable.

[note: there have not been any press releases but excerpts from a recent interview in Perfumers & Flavorist magazine. I doubt the quotes were entirely on message.]

Synthetic Fragrances and Essential Oils Improved Health and Environmental Criteria

Great news. The two year effort to develop environmental criteria coupled with human health data is now before the USA EPA management for internal review. Official comment is expected next month since the submission was accepted early December 2009. Be assured adherence to the criteria will provide a clear quick pathway to safe fragrances used in cleaning products.

Criteria details- The ETF (Environmental Task Force) which was organized by CleanGredients and EPA's Design for the Environment department, agreed to use specific screens based on the submitted criteria in the as-applied cleaning product for DfE's partners as follows:
1) the DfE General Screen for non-essential oil materials contained in confidential fragrance formulas at or above 0.01%
2) the High Capacity for Biodegradation Screen for essential oils or constituents there of at or above 0.01%
3) the EPI Suite Screen for fragrance materials present under 0.01%

The three screens will serve to drive data collection for higher volume-use fragrance materials and essential oils currently in the market place. This should resolve the data gaps needed for scientific relevance and policy.

Next steps- once EPA favorably responds there is general ETF agreement that two more months will be needed by the supply chain and suppliers to develop a response to their clients on the effect to existing and future formulas. Also, in order for the industry to maintain their current practices and trade secrets, a Trade group will need to build the data base for access. Currently IFRA has just published a list of all tested materials used in perfumery for all applications including cleaning products. Based on formula transparency concerns, IFRA's due paying members will be looking for further Board action.

As clear and easy the three screens will be to use and apply, there will remain complications regarding current market claims by the formulators. For example, playing on emotions and a different scientific basis, essential oils in cleaning products have been promoted with similar benefits as in personal care products. Aside from smelling nice, chemically, essential oils do harm the environment when rinsed down the drain. Technically, the grades that are affordable for cleaning products are not as refined to the safety standards used in Toiletries. There are no replacements for what Nature originally intended and evolved. This misdirection needs to be untangled as many companies "greened" their products with essential oils based on positive consumer cross product conditioning.

A Green Nose caution- the second screen, High Capacity for Biodegradation, was suggested by a special ETF sub-panel to screen perfume material that have little to no water solubility.The chemical make-up of the material still needs to pass other screens. This is not intended to be a dodge for an essential oil that is claimed to be a fixative or provide a physical benefit for a formula.

Are we There Yet?

Received word that the EPA management now has the Environmental and Human Health Fragrance /ETF criteria to review. While this is pending, every effort should be made to decide WHO will build the data base, and when will the information be distributed, updated and open source to all fragrance creators, product formulators, NGO's, state EPA's, and retail chains that make green declarations.

WHO will actually make the effort to first meet, share goals, and publish data? It's been suggested by the Fragrance Technical Committee that RIFM (Research Institute for Fragrance Materials) and CleanGredients have an initial discussion. Both organizations have a charter to be useful and informative to their members. And can the FMA (Fragrance Material Association) contribute, whose members is the supply chain? These folk understand the impact. Why can't they publish a list?

Look, we know the fragrance consultants and third party reviewers are not going to give up information that generate fees. And we know the fragrance in-house regulators can only construct turducken system checks because they do not formulate.

In the meanwhile, fragrance houses will be using their GC to copy known DfE formulas that come from extractions or shopped compounds for improvement, Perfumers and some regulators will be privately circulating DfE approved material lists, PR statements will be released, IFRA will have published material lists as they pertain to EU REACH, sadly existing Institutional and Consumer products will continue to make sustainable, natural (or Organic), safe claims for Essential Oil blends that are environmental hazards all while the EPA is taking action steps regarding clean water and our deplorable water treatment capabilities.

Are we there yet? Are all the myths and past practices deconstructed enough to make sense for an industry that now, today, has merged data and criteria on human health and environmental concerns. It's not yesterdays news, it's tomorrows action that matters.

Happy New Year 2010.

Orcas

This Fall I attended a series of lectures by Brent Nixon. Perhaps the most compelling talk was on Orcas. This particular species is studied extensively from population statistics to pod structure and behaviors. Amazingly, nearly every Orca is observed whether it is transient or thrives in a resident pod. And every resident pod is matriarchal and ruled by the grandmother who survive up to ninty years.

What stuck me most is due to the effects of bioaccumulation, as they feed at the top of the food chain, adult females transfer up to 90 percent of environmental contaminants to their first born calf. According to Mr. Nixon, the result is 100 percent death rate. The following calves do fine and their mortality rate is more happenstance.

I looked for collaboration to the first born mortality statement. I also found scientist have been confounded for decades by the disappearance of calves and deducted to only count them in their population records after the calves were two years old.

How does one make sense of this? Do we resign our responsibility to let Orcas remain amusements for Sea World or "killer whale sightseeing rides?" Can we not see the sense that fragrance materials that are known hormone disruptor's or aquatic toxins might contribute to the Orca situation? Do we continue to negate these emerging chemical measurements when the solution is to simply revise our formulas now for fragranced products that are rinsed down the drain?

Mothers, would we be a trifle overwrought if our first grandchild does not survive their first year?

Banned IF Born Before 1970

Yesterday the long expected announcement on Green Indexing came out from Wal-Mart. This announcement by Matt Kistler, W-M Senior VP of Sustainability, will be mistakenly considered initially a change of direction. But the intent has always been to find a responsible way to effect development of green sustainable products. The Green Nose has stated that the ability to establish an index with known criteria is possible with fragrance chemicals, an important ingredient additive in nearly every leading consumer and institutional cleaners.

What is the impact when Wal-Mart announces an indexing programs to the manufacturing companies and the chemical supply chain? One, despite protests, real costs for specialized components will go down slightly. Initially, learning new analytical methods,  plus regulatory reporting will have a resource impact but reduced inventory of acceptable formula materials and resultant market forces will succumb to fair pricing. Wal-Mart is negating any manufacturer's threatened price increase argument by saying they will pass on the cost if necessary.

Two: product index labeling will result in chemical transparency and consumers will have another level of choice and personal benefit. Will transparency ruin confidentiality? No, because product intellectual protections (IP) are already in place and enforceable if a company is harmed. IP were necessary because competitive products are easily analyzed and reversed engineered in any modernly equipped lab. Leading formulators have recently set up ingredient disclosure summaries on their websites.

Three: toxicologist, environmentalist, and marketers do agree that prevention is the only acceptable environmental creed to follow. Buzz phrases like eco-babble are only stall tactics while industry self-regulators cry for standards and definitions.  

Not surprising, almost all of the preeminent industry regulators who participated in the dialogue were never educated in environmental sciences. That is why Non Government Organizations as well the EPA play a vital role in the process.

Wal-Mart in their releases has assessed that their program may take years to fully implement. Current programs in Europe are still gestating and differ with political boundaries. But the Wal-Mart goal is very noble and meant to effectively serve their target consumer and a global economy in the next decade. This is an opportunity to eliminate two key concerns found in certain fragrance materials. That is endocrine disruptor's and aquatic toxins that enter our waterways from cleaners that are rinsed down the drain. 

If you were born before 1970, you fumbled your chance for real leadership, stewardship and responsibility for clean waterways for your children. Your wisdom and experiences will now become a reflection on possibilities. High praise to Wal-Mart to support green sustainable chemistry for the market place.