“behind the green curtain”

The information and suggestions herein are believed to be reliable but are not to be construed as warranties, nor a guarantee against patent infringement. HARCROSChemicals Inc.

“Behind the Green Curtain”

Terri GermainAugust 3, 2009


“Green” is…

Safe?

Environmentally Benign?

Low Toxicity?Safe for Aquatics?

Biodegradable?

Natural?

Organic?

Renewable?Sustainable?

Low VOC?

Energy Saving?

Water Conservation?


“Green” Environmentally Friendly Products

Have Some of These Attributes Readily Biodegradable Non-Toxic & Non-Sensitizing Low Aquatic Toxicity Low or No VOCs Neutral pH at Use Non-Combustible/Flammable Concentrated Formulations Works Well in Cold Water Recyclable Packaging From Renewable Resources

Generally Do Not Contain Phosphorus compounds Hypochlorite Phenolic compounds Ethylene Glycol Ethers Carcinogens Heavy metals Phthalates Alkylphenol Ethoxylates


The U.S. Federal Trade Commission (FTC) and the International Standards Organization (ISO) consider this claim to be too vague to be meaningful to consumers. The FTC guidance requires manufacturers to either avoid such terms or substantiate and qualify them to avoid misleading consumers. To comply with the ISO standard for environmental claims (which is voluntary), companies must not use them on their products.


Just a Few Initiatives….

Good Environmental Choice Sweden

Green Seal US NGO

Environmental Choice Canada

Detergents Directive EU

Design for the Environment US EPA

Ecocert France

Environmentally Preferred Purchasing US EPA

Nordic Swan Norway, Sweden, Denmark, Finland, Iceland

EcoLeaf JEMAI & MITI Japan

Blue Angel Germany


Let’s Focus a Bit on Ingredients…

#1 Where it came from… Renewable Resource “Organic” Vegetable vs Animal Recycled Feedstock

#2 Where it’s going… Environmental Fate

• Biodegradability

• Aquatic Toxicity

Remember, Green is also about Safety (Neutral pH vs very high of very low pH), Energy Consumption (Hot water vs Cold Water), Packaging (recycled, post

consumer), Concentrate vs RTU, Transportation (Local ingredients vs transoceanic)

And on, and on, and on….


#2 Environmental Fate Key Drivers

• Biodegradability• Aquatic Toxicity• No Carcinogens

Common U.S. Green Certifiers• EPA’s Design for the Environment (DfE)• GreenSeal• EcoLogo (Canada)


Design for the Environment (DfE)www.epa.gov/dfe/index.htm

I&I Partnership DfE's Formulator Program encourages partners to reformulate products to be

environmentally safer, cost competitive and effective. The Formulator Program reduced ~ 160 million pounds of chemicals of concern in 2007.

Many of the industry's major I&I players are already or are in the process of becoming DfE partners.

State govt purchasing entities now include DfE recognition in their specifications for eco-friendly products.

Consumer Products Partnership DfE is now working with the consumer cleaning products sector. DfE has also partnered with Wal-Mart's Chemical-Intensive Product Network

to develop sustainability scorecards for suppliers and manufacturers.


DfE Formulator Program Steps to Partnership

1. Contact EPA DfE to discuss product submissions.2. Search for safer ingredients on CleanGredients™. 3. Request 3rd-party ingredient profiling.

• NSF International and ToxServices are qualified to provide this service.

4. Submit ingredient profiles to EPA DfE.• Sent by third-party on behalf of the formulator.

5. Review ingredient profiles – EPA technical workgroup.6. Post-assessment discussion with submitter.7. Sign partnership agreement.

• 3-year agreement between formulator and EPA


DfE Formulator Program Steps to Partnership


NSF Third Party Review Costs

Fee Per Product

$400 A one-time, flat fee charged for each product or unique trade name: (includes administration, data entry, and summary report)

Fee Per Ingredient

$525 Single ingredient (first time review; includes complete literature search and data validation)

$1050 Proprietary ingredient (first time review, includes contacting supplier, complete literature search and data validation)

$1250 Fragrance (first time review)

No Charge Pre-reviewed ingredients (includes ingredients listed on CleanGredients or previously reviewed for your company

Fees as of July 2008 – Contact NSF for updated pricing


DfE Standard Surfactant Screen Must not contain CMRs

(Carcinogenic, Mutagenic or Toxic to Reproduction) Must not Bioaccumulate Aquatic Tox and Biodegradation

Acute Aquatic Toxicity(L/E/IC50 Value)1

Rate of Biodegradation

≤1 ppm May be acceptable if biodegradation2 occurs within a 10-day window without products of concern3

>1 ppm and ≤10 ppm Biodegradation2 occurs within a 10-day window without products of concern3

>10 ppm Biodegradation2 occurs within 28 days without products of concern3

1. In general, there is a predictable relationship between acute aquatic toxicity and chronic aquatic toxicity for organic chemicals, i.e. chemicals that have high acute aquatic toxicity also have high chronic aquatic toxicity. Since acute aquatic toxicity data are more readily available, the DfE Screens use these data to screen chemicals that may be toxic to aquatic life.

2. Generally, >60% mineralization (to CO2 and water) in 28 days.3. Products of concern are compounds with high acute aquatic toxicity (L/E/IC50 ≤ 10ppm) and a slow rate of biodegradation (greater than 28 days).


Design for the Environment (DfE)Detergent Ingredients Partnership

DfE has partnered with the GreenBlue Institute to develop a tool for easy, reliable identification of ingredients with optimal performance and environmental characteristics.

CleanGredientsTM at www.cleangredients.org CleanGredientsTM was developed by a multi-stakeholder

advisory committees and includes Surfactants and Solvents An ingredient in listed as “not meeting DfE criteria” does not

mean it cannot be used. • The formulator must have a case for the use – such as “there is

nothing better in the market place for this application.”

• Each year the DfE will ask the formulator the question and the answer has to be the same.


www.cleangredients.org


Green Seal Standards Degreasing Agents in Production and Maintenance

Operations (GS-34) Consumer Soaps, Cleansers, and Shower Products (GS-44) General-Purpose, Bathroom, Glass, and Carpet Cleaners

Used For Household Purposes (GS-8) Industrial and Institutional Cleaners (GS-37) Hand Cleaners and Hand Soaps Used for Industrial &

Institutional Hand Purposes (GS-41) Industrial & Institutional Floor Finishes and Floor Finish

Strippers (GS-40) Laundry Care Products (GS-48) In development


Green Seal Standards Primary Criteria

• Non toxic• No Allergens, Carcinogens, Mutagens, and Reproductive Toxins• Not Skin Corrosive or Capable of Serious Eye Damage• Not a Skin Sensitizer or Primary Skin Irritant• < 1.0% Skin Absorbing Ingredients i.e. Governmental Industrial

Hygienists (ACGIH) Threshold Limit Value list (TLV) carrying a skin notation, or substances that are listed on the German Deutche Forschungsgemeinschaft (DFG) Maximum Allowable Concentrations (MAK) list with a skin absorption H notation.

• Does not cause Asthma• Generally < 1.0% VOC• Low Aquatic Tox and Good Biodegradability

Full Listing at http://www.greenseal.org/certification/environmental.cfm


Trouble with Green Seal Standards?

CRI Withdraws Support for Green Seal Standard• GS-37 measures product efficacy against a "nationally recognized"

product rather than against an approved standard.

• GreenSeal did not allow the participation of all stakeholders in the development process for GS-37

• GS-37 arbitrarily bans chemicals according to a list, without regard for proper risk assessment - a practice which runs contrary to accepted scientific practices.

• At various points, it seemed that peer-reviewed scientific data was discounted in favor of preconceived bias on the part of the standard developers.

• GS-37 4th Edition was released without a second ratifying ballot, even after a first ballot failed to achieve a majority.


HI&I “Green” Requirements DfE and Green Seal require:

• Aquatic Toxicity Data DfE requires ready biodegradability of ingredients if aquatic tox is GHS Acute

Category I or II Green Seal has different requirements for different standards. Generally they

require ≥ 100 mg/L LC50 of daphnia, fish and/or algae on finished product at use

• Biodegradation Data DfE requires Readily or Ultimate Biodegradability Green Seal has different definitions and requirements for biodegradability Both will accept OECD testing that EU Authorities are requiring

Green Seal has many more requirements involving VOCs, carcinogens, sensitizers, fragrances, dyes, prohibited ingredients, etc.

Packaging and Use Instructions are also part of “Green.” Neither require that ingredients are derived from Renewable Resources!


#1 Resource Utilization Key Drivers for “Natural”

• Renewable Feedstock aka Renewable Carbon• Organic• Reduction and/or Elimination of PetroChemicals

Common Natural / Organic Standards• USDA’s National Organic Program• Ecocert• National Products Association• Oasis


Natural & Renewable Based A step toward Sustainable Chemistries

• Allows use of limited resources for other needs Can be calculated two ways

• Vegetable content of surfactants For example: 55% the active surfactant

Cocamidopropyl Betaine is vegetable derived.

• “New” Carbon vs “Old” Carbon For example: 65% of the carbon atoms in the active

surfactant Cocamidopropyl Betaine are “new” carbons meaning vegetable derived.


Sodium Coco-Sulfate Na+

SO O

O

O-

Mackol CAS-100N


Cocamide MIPA / Coco monoisopropanolamide O NH

OH

Mackamide CPA


ww

w.g

reen

star

prod

ucts

.org

Means 76% is Natural Derived


Natural & Renewable Vegetable Content Ranges (based on solids)

30-50% 50-70% 70-90% >90%Mackam Alkyl Propionates

Mackam Amphoacetates

Mackam Betaines Mackam Sultaines

Mackanate Sulfosuccinates

Mackadet Blends

Mackam Betaines (from Triglycerides)

Mackamine Amidopropyl Amine Oxides

Mackamide DEA Amides

Mackol AnionicsMackaderm Guerbet Esters

Mackadet Blends

Mackine Amido Amines

Mackadet SoapsMackamide MEA & MIPA Amides

Mackester Phosphate Esters

MackproPlus Cationic Proteins

Mackamine Alkyl Dimethyl Amine Oxides

Mackol Fatty Acids

Mackol Alkyl Glucoside

Mackester Pearlizing Esters

Mackaderm Specialty Emollients

Mackstat GCM Preservative


Clear & Natural Shampoo Ingredient

% by Weight

Function

Water, soft QS Carrier Mackadet® CSB Sodium Coco-Sulfate,

Cocoamidopropyl Betaine, Disodium Cocoamphodiacetate, Disodium Oleamido MIPA-Sulfosuccinate, Glycereth-26

30.0-35.0 Vegetable derived cleansing agents

Mackernium® SFES or CC112P9 Sunflowerseedamidopropyl / Isostearamidopropyl Ethyldimonium Ethosulfate (and) PEG-9

0.65

Slip Agent/Conditioning agent

Citric Acid QS pH/Viscosity adjust

Sodium Hydroxide, 50% QS pH/Viscosity Adjust

Phenagon® PBD Phenoxyethanol (and) Benzoic Acid (and) Dehydroacetic Acid

0.7-1.0 Formaldehyde and Paraben Free

Preservative

Formula #708

No heating requiredAll surfactants and conditioners are vegetable derivedFormulation solids is 46% vegetable contentFormaldehyde-free

No heating requiredAll surfactants and conditioners are vegetable derivedFormulation solids is 46% vegetable contentFormaldehyde-free


Surfactant Producer Approaches Stepan

• “Biorenewable Carbon IndexTM”

Cognis• “Green Chemical SolutionsTM”

McIntyre (Rhodia)• “Naturally Mild”


Allowable Chemical Processes

USDA NOP and NSF Organic• Hydrolysis, e.g. Wheat Amino Acids• Esterification, e.g. Glyceryl Stearate• Saponification, e.g. Sodium Cocoate

OASIS & NPA• Everything above plus…• Sulfation, e.g. Sodium Coco-Sulfate• Hydrogenation, e.g. Hydrogenated Palm Oil• Hydrogenolysis, e.g. Hyd. Palm Alcohols


Allowable Chemical Processes

OASIS & NPA (continued)• Etherification, e.g. Polyglyceryl Stearate• Glycosidization, e.g. Lauryl Glucoside• Acylated amino-acids, e.g. Lauroyl Glutamates

Ecocert• Everything above plus…• Amphoterics & Betaines• Cationic Guar


Whole Foods Premium Body Care Quality Standards

• “People are looking for safer, more natural body care products, but there is a lot of confusion about what "natural" actually means. So, with more than 25 years of experience and 2 years of tough scientific research review, we have stepped up to help give concerned consumers something to count on.”

Standard List Last Updated 2/15/2008


Who’s Green? Anyone Who’s Anyone!

S.C. Johnson

Clorox

Spartan

ReckittBenckiser

Zep

Procter & GambleSeventh Generation


Summary If anyone asks you for “green” ingredients

ask them:• Green …like from natural renewable resources?

or..• Green …like DfE and GreenSeal with

biodegradable and low aquatic toxicity?

or…• Both?

If anyone asks you what “green” is…• It is still blue +

“behind the green curtain”

Documents

dfe formulator program

dfe partners

partnershipcontact epa

dfe recognition

party ingredient

low ph

vs rtu

single ingredient