natura – managing eco-toxicity of ingredients in...
TRANSCRIPT
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Danny Castonguay - Natacha Hardy - Rachita Pandey - Mio Yamamoto
Natura - Managing Eco-toxicity of Ingredients in Cosmetics
15.915 – Laboratory for Sustainable Business
May 16, 2012
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Table of Contents
1 Introduction ............................................................................................................................................ 3
1.1 Objectives ........................................................................................................................................ 3
2 Methodology .......................................................................................................................................... 4
2.1 Research ......................................................................................................................................... 4
2.2 Interviews ......................................................................................................................................... 4
3 Global Trends ........................................................................................................................................ 4
3.1 Evolution from hazard assessment to risk assessment .................................................................. 5
3.2 Evolution from hazard assessment to risk assessment .................................................................. 6
3.3 Rise in Industry self-regulation ........................................................................................................ 6
3.4 Conflicting guidelines between Industry Standards - Cosmetics Directive and REACH................. 7
3.5 Growing emphasis on risk management and risk communication .................................................. 7
3.6 Development of various tools .......................................................................................................... 8
4 Emerging Good Practices ..................................................................................................................... 8
4.1 Assessment Tools ........................................................................................................................... 8
4.2 Applications of Emerging Good Practices ....................................................................................... 9
4.2.1 LION ...................................................................................................................................... 9
4.2.2 Herman Miller ........................................................................................................................ 9
5 Decision Framework ........................................................................................................................... 10
5.1 Motivation ...................................................................................................................................... 10
5.2 How it Works.................................................................................................................................. 11
5.3 Parameters .................................................................................................................................... 12
5.4 Actions ........................................................................................................................................... 13
5.5 Rules .............................................................................................................................................. 14
5.6 Next steps ...................................................................................................................................... 15
5.6.1 Discover new parameters, actions, and rules ..................................................................... 15
5.6.2 Test in practice .................................................................................................................... 16
5.6.3 Objectives and goals ........................................................................................................... 16
6 Conclusion ........................................................................................................................................... 17
7 Appendix ............................................................................................................................................... 1
7.1 Appendix 1 – Key Research References ........................................................................................ 1
7.2 Appendix 2 – Contact information of people we connected with ..................................................... 2
7.3 Appendix 3 – Comparative Analysis of Hazard, Exposure and Alternatives Assessment Tools .... 3
7.4 End Note .......................................................................................................................................... 5
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1 Introduction
1.1 Objectives When looking at sustainability from a global perspective, the chemical industry has a significant impact
on both human health and environment. Consumer products including cosmetics and personal care
products compose about 10% of the worldwide chemical turnover of more than three trillion dollars.12
From the life-cycle viewpoint, chemical ingredients of these products have potential to affect eco-
systems through exploitation of resources, manufacturing, transportation, consumer use, and disposal.
Especially, for the products like shampoo and sunscreen, their release into water following the
consumer use does affect not only the environment but also human health through drinking water,
accumulation in organisms, soil, and air. Given such recent growing concerns about the eco-toxicity as
well as human-toxicity of chemicals, Natura picked eco-toxicity management as a topic of this S-Lab
project.
Natura is a Brazilian cosmetics, fragrance and personal hygiene company established in 1969. They are
currently a market leader in Brazil with about 7,000 employees. They provide over 900 personal care
and cosmetic products whose main ingredients were often discovered in the wild nature of Brazil.
Natura states, “our reason for being is to create and sell products and services that promote well-
being/being well” and put strong emphasis on quality and care for people.3 As an international brand,
Natura’s main concern is how Natura can design and implement its eco-toxicity management in a way
that aligns with its mission.
This report focuses on how to manage eco-toxicity of the product use and down-the-drain disposal
stages in this project, because they are the major pathways in which chemicals of consumer products
affect the environment. Natura already has the obligation to comply with a set of environmental
regulations; nevertheless, as part of their philosophy and strategy, they want to be pro-active in this
area. In order to help them to address this issue, our objectives are:
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Identify current worldwide trends and good practices in eco-toxicity management
Propose a strategic decision-making model to deal with eco-toxicity of ingredients of their
products
2 Methodology
2.1 Research Our main source of research was Internet. We gathered information from a number of government and
corporate websites regarding the current trends and established industry standards in managing eco-
toxicity of cosmetics ingredients. Information provided by Natura also proved very helpful in
understanding the significance of eco-toxicity in the cosmetics industry. We studied Natura’s proprietary
documents to establish the scope of our project and decided to focus on the use-phase of cosmetics. We
also referred to books and journals that carried case applications of emerging good practices in
managing environmental risk of chemicals and ingredients. Key references are listed in Appendix 1.
2.2 Interviews We interviewed experts from academia and industry to learn more about the emerging good practices
in the field of managing eco-toxicity of ingredients. The list of people we connected with is presented in
Appendix 2. It emerged during our discussions, as highlighted in Appendix 3, that the cosmetics industry
is still in its early stage of developing good practices related to ingredient eco-toxicity.
We discuss the highlights of our research and the interviews in the following section.
3 Global Trends
Managing eco-toxicity of products and ingredients is relatively new to the chemical industry. However,
with rising public concern about the sustainability of products, the field is gaining greater attention from
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companies, non-profits and governments. Through our research and interviews, we have identified the
following current industry trends in managing eco-toxicity of chemicals and ingredients:
Evolution from hazard assessment to risk assessment
Increase in legislations worldwide
Rise in Industry self-regulation
Conflicting guidelines between Industry Standards - Cosmetics Directive and REACH
Growing emphasis on risk management and risk communication
Development of various tools
3.1 Evolution from hazard assessment to risk assessment The approach to deal with hazardous chemicals has evolved from hazard assessment to risk assessment.
Hazard is the intrinsic ability of a chemical substance to cause adverse effects on human health and
environment. Risk, on the other hand, is the probability that such effects will occur. Risk assessment
takes into account both the hazards of a chemical substance and its exposure to human health and
environment4. For instance, if an ingredient is less toxic but a large volume is released into the
environment, its aggregated impact should not be ignored. The relationship between risk, hazard and
exposure is expressed as:
Risk = f (Hazard, Exposure)
A popular technique to measure risk is using the risk quotient, which is the ratio of PEC (predicted
environmental concentration) to PNEC (predicted no effect concentration).56 If the ratio is greater than
1, the substance may cause damage to the environment. While this calculation is somewhat simplistic
and further examination is expected, this approach is widely used in regions including European Union
(EU), US and Japan. We use this quotient in our study to assess the potential adverse impact of
ingredients on the aquatic environment.
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Global initiatives on chemical management have embraced the risk-based approach since 1990’s,
replacing the hazard-based approach. In 1992, Agenda 21 was agreed upon as a set of action plans,
including expansion and acceleration of international assessment of chemical risks7 at the United
Nations Conference on Environment and Development in Rio de Janeiro. Strategic Approach to
International Chemicals Management (SAICM8), adopted at the International Conference on Chemicals
Management in 2006, also covered risk assessments of chemicals to achieve the goal that, “by the year
2020, chemicals are produced and used in ways that minimize significant adverse impacts on the
environment and human health.”
3.2 Evolution from hazard assessment to risk assessment Although EU has spearheaded regulations on chemical management, governments across the world are
now tightening their laws around chemicals adversely affecting the environment. EU’s REACH governs
the evaluation of all industrial chemicals from their production to disposal, requiring companies to
register all the chemical substances manufactured or imported in more than the specified quantity.
USA’s EPA and other similar legislations from countries such as Japan and Canada are now placing
greater emphasis on a risk-based approach than the traditional hazard-based approach in reducing
adverse environmental impact of chemicals. In 2013, a REACH-like law will come into effect in South
Korea as well. Discussing each country’s legislation is beyond the scope of this project; however, more
and more countries are updating their domestic legislations to meet international agreements on
managing environmental risk of chemicals.
3.3 Rise in Industry self-regulation In addition to the government legislations, voluntary regulations have been promoted at the industry
level. International Council of Chemical Associations (ICCA)9 has developed programs that support
SAICM including Responsible Care and Global Product Strategy (GPS). The Responsible Care is adopted in
60 countries, where more than 70% of world’s chemicals are produced. ICCA also collaborates with the
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Organization for Economic Co-operation and Development (OECD) in the High Production Volume (HPV)
Chemicals Initiative to collect and share hazardous data across the industry and countries. These
voluntary initiatives at the global level are adopted at individual country level by chemical industry
associations such as Japan Initiative of Product Stewardship of Japan Chemical Industry Association and
Atuação Responsável of Brazilian Chemical Industry Association (ABIQUIM).10
3.4 Conflicting guidelines between Industry Standards - Cosmetics Directive
and REACH An increase in the number of regulations on chemical management has raised the probability for
conflicting goals between these standards. In addition, cosmetics are governed both by the regulations
on chemical substances and also by those on cosmetics. One such challenge the cosmetics industry is
facing today is the tension between two regulations regarding animal testing. Cosmetics Directive issued
by EU bans certain animal testing of cosmetics ingredients, while REACH requires animal testing for
safety data.11 12 13 14. According to Naohiro Takahashi, “although there are ways to balance the
tension, it would be harder to get approval for new substances without necessary data record to prove
their safety.”15 It may be important especially for Natura to watch these regulations as using natural
ingredients is one of Natura’s value propositions and substances derived from newly discovered natural
ingredients might not have all the necessary data.
3.5 Growing emphasis on risk management and risk communication Risk assessment based on hazard and exposure data is not proving sufficient in managing eco-toxicity of
products and ingredients. The next step has evolved to risk management. This evaluates whether the
assessed risk needs risk mitigation efforts, if so, decide how to control the risk, implement the actions,
and monitor the results. Another the critical aspect of risk management becomes risk communication,
which is to provide necessary information to all the stakeholders including consumer, industry, and the
regulatory bodies. The results of risk monitoring and communication are increasingly being included
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back into the risk management process to form a feedback loop to enable future decision-making in risk-
control. The growing emphasis on risk management and communication can be observed from
documents such as OECD Environmental Risk Assessment Toolkit.16
3.6 Development of various tools As part of the emerging good practices in managing eco-toxicity of products and ingredients, various
tools have been developed in the industry that assess environmental risk from chemical hazard and/or
exposure and sometimes also evaluate safer alternatives. These tools have been developed by
governments, international associations and non-profit organizations across the world and are helping
an increasing number of companies and consumers today to make informed decisions about using
various substances.
However, each tool focuses independently on some aspects of risk management, such as assessing
hazard or exposure, or assessing safer alternatives. Not many tools focus on the cosmetics industry
alone and none look at combining hazard, exposure and alternatives assessment into one framework.
Based on our research, we have identified a number of good practices that could be useful to Natura. In
the following section, we present a few of them and also discuss two cases applications of these
emerging practices.
4 Emerging Good Practices
4.1 Assessment Tools Appendix 3 presents a comparative analysis of a few publicly available tools that we believe Natura may
utilize in developing a risk management approach for their cosmetic ingredients and products. We
comment on what these tools do not offer that could have helped Natura in developing a more holistic
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risk management framework and hence leave scope for a comprehensive framework. Moreover, we also
draw attention to the tools that can serve as marketing instruments for Natura.
4.2 Applications of Emerging Good Practices
4.2.1 LION LION Corporation17, a manufacturer of detergent, soap, medications, oral hygiene products, and other
toiletries headquartered in Japan, has developed products that address environmental issues. One of
such initiatives resulted in the development and first industrial production of methyl ester sulfonate
(MES) and methyl ester ethoxylate (MEE).18 MES and MEE are plant-based surfactants with excellent
detergency and biodegradability. MEE is as effective as the traditional detergent with only half the
amount.
LION participates in the risk monitoring conducted by Japan Soap and Detergent Association to evaluate
the impact of surfactants used in household detergents on aquatic environment in urban rivers. 19
All the ingredients used by LION are managed in their internal database with Material Safety Data Sheet
of each ingredient to support its risk communication with suppliers, customers, and other
stakeholders.20
4.2.2 Herman Miller
Herman Miller has developed its own Design for environment (DFE) tool together with MBDC21
that
consists of a proprietary materials database to consider the safety and environmental impacts of each
material and classifies them into one of four categories: green (little to no hazard), yellow (low to
moderate hazard), orange (incomplete data) and red (high hazard). The tool considers four factors for
each component in the product:
Material Chemistry: Fraction of the materials by weight that are the safest possible in terms of
human toxicity and environmental concerns
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Recycled Content: Fraction of the materials by weight that are post-industrial or post-consumer
recycled content
Disassembly: Fraction of materials by weight that can be readily disassembled
Recyclability: Fraction of the materials by weight that are recyclable
Over time, Herman Miller aims to use only materials that rank yellow or green for all new products. For
example, polyvinyl chloride (PVC) is classified as a red material. It is used commonly in furniture due to
its low cost and high strength. However, both the production and incineration of PVC releases toxic
emissions. Herman Miller decided to entirely avoid using PVC in its new products and refined its
engineering design process to use safer materials such as polypropylene instead.
5 Decision Framework
5.1 Motivation Most environmental risk assessment frameworks available in the industry today include either potential
hazard or exposure or both criteria to evaluate safety of chemical ingredients, in addition to regulations.
However, our research indicates that no model considers the softer parameters such as risk perception
of the ingredients in society, patents on ingredients and growth trends associated with the use of those
ingredients in the market.
Moreover, none of these
frameworks focus only on cosmetic
ingredients but rather present a
generic model to assess safety of
products and ingredients in all
industries. We aimed to fill this gap
by developing a decision framework for cosmetic ingredients, which considers a wider set of parameters
to evaluate a set of actions that can be taken in managing eco-toxicity of ingredients.
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Of primary importance is that the decision framework be seen as an objective measure to compare
ingredients and their potential substitutes on an equal footing. At a minimum, for the user, the exercise
of gathering the data to feed the model is a reminder of the need to consider several dimensions in the
decision making process. Equally important, the framework is a way to force the decision maker to use
the same method and data formats to compare ingredients and their substitutes. Ultimately, the
decision framework does not claim nor aim to be a replacement for sound human judgment but rather
an analytical support tool.
5.2 How it Works The Decision Framework feeds on a combination of one cosmetic ingredient and one possible substitute
and then makes recommendations about the future use of that ingredient. The recommendations are
based on the relative confidence with which specific actions can be taken in managing the ingredient in
future. Every action, in turn, is based on certain business rules that reflect real world business scenario.
The model itself should also periodically be tweaked, to adjust and update the decision-making rules.
Although the action sets are recommendations, they are by no mean prescriptive. Instead, the
framework is meant to suggest that decision makers should consider more carefully certain actions over
others, on a scale from 0 to 100, where 100 implies a high level of confidence in the action. We present
below the list of parameters, the business rules and the recommended actions that are modeled in the
framework.
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5.3 Parameters We considered a list of parameters that could affect decision-making related to eco-toxicity of
ingredients and selected the following in designing the model:
Risk quotient (PEC/PNEC, Predicted Environmental Concentration / Predicted No Effect
Concentration) - if the ratio is greater than 1, the substance may cause damage to the
environment
Perception (subjective assessment of the customer perception, assigning a 0-100 value for this)
– this assessment may be subjective, but the same method should be applied for all ingredients
and should be normalized to obtain a meaningful distribution
Policy (likelihood that in the near to medium term the product will remain legal and will not
have an regulation limiting its usage)
List of all products containing the ingredient (and concentration per product)
Ingredient cost (R$/liter)
Annual revenue and gross profit derived from each product sold
Annual volume of each product sold (last year, or next year’s estimates)
Growth trend for each product (percentage year over year)
Geography where each product is sold (the volumes broken down by geography)
Information regarding relevant patents (as expressed in number of years of patent outstanding)
List of potential substitutes, and for each substitute
o Risk quotient, perception, policy, cost, and patent information (similar to ingredient it is
replacing)
o Availability in liters - what quantity of substitute could be procured at the time the
substitution needs to be done (for bulk of products concerned)
o Relative performance in the end product as compared to ingredient it is replacing - how
does the substitute compare to the substituted ingredient?
o Measure of the complexity of replacing the ingredient in the manufacturing process - this
measure should also reflect the time required for making the change (or reversing it)
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In the hypothetical example above, comparing BHT versus its substitute, the following could be a
comparison of their parameters.
We see that the risk quotient is better for the substitute, that the performance is almost equal but that
the substitute is more than twice as expensive. If such a substitute existed, we would expect that Nature
would strongly consider replacing BHT with this ingredient.
5.4 Actions Based upon these parameters, we analyzed potential risks and costs associated with these potentially
hazardous substances or products containing them. Based upon our decision framework, we then
defined the following actions for managing the ingredients:
Advertise the ingredient more
Maintain status quo
Attempt to lower cost of the substitute
Do more research on the substitute
Replace with the substitute
Cease production with the ingredient
Parameter Units BHT BHTsubs11
Risk quotient Positive number 1.7 0.8
Perception Scale: 0(neg)-50(ignore)-100(pos) 20.0 45.0
Policy Scale: 0(neg)-50(ignore)-100(pos) 80.0 90.0
Performance Scale: 0(worse)-50(same)-100(better) 48.0
Cost $/liter $ 5.00 $ 12.00
Quantity/Availability M liters 226.3 50,000.0
Patents Years to expiration (0=no patent) 3.6 4.5
Complexity Years required to make the substitution N/A 2.7
Gross profit $M (allproducts) N/A 22.0
Ing: Growth trend % y/y N/A 4%
Ing: Geography ISO 3166-1 BR BR
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The framework is designed such that these actions are not mutually exclusive. It gives the relative
confidence with which these actions can be taken in the best interest for the environment and the
business.
Not all combinations of recommendations are equally likely. For example, it would be hard to make
sense of a situation where the framework would recommend simultaneously to “advertise the
ingredient more” and to “cease the production with the ingredient”. However, it is conceivable the
decision framework would score high the any combination of the last four actions at the same time. So
for example, we could imagine that the company should “do more research on the substitute” and
“replace the ingredient with the substitute”.
In the previous example for BHT, the framework scored very high the action to replace BHT with
BHTsubs11 (85 points). In some sense, this should give a good confidence behind the decision to follow
the action, but a careful decision maker should probably try to understand what rule is contributing to
the 30 points under “cease production”.
5.5 Rules We developed a set of rules that reflect different possible scenarios of an ingredient matching with a
substitute. Every action, discussed above, is associated with these rules before making
recommendations. Following is a list of few possible business rules:
Advertise the ingredient more: If the ingredient has a risk quotient less than 1, the public
perception is positive, there are no policies against it, the gross profit is significant, is growing in
usage per year, Natura has a patent on it, the substitute does not perform as well and the
substitute is not less toxic and the substitute does not have a good perception
Maintain status quo: If the ingredient has a risk quotient less than 1, there are no policies
against it, the substitute does not perform as well and the substitute is not less toxic, the profit
impact of using the substitute would not be overly worse than that of continuing with the
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ingredient, the substitute would not be available once the complexities of substituting would be
overcome
Attempt to lower cost of substitute: If the substitute is available once the complexities of
substituting would be overcome, it performs better, is not too complex to implement, but its
cost is prohibitively expensive
Do more research on the substitute: If the ingredient has a risk quotient more than 1 and the
substitute is not better (either performance or risk)
Replace with substitute: If the substitute is better than the ingredient and there is enough
available to substitute and the gross profit impact is not too adversely large
Cease Production: Both the ingredient and the substitute are harmful and the public perception
is negative for both
5.6 Next steps
5.6.1 Discover new parameters, actions, and rules
The decision framework is a data driven analytical tool. As such, it needs to remain simple enough that
insights can be intelligible and understood by its users. Concurrently, it needs to capture all the
subtleties of what goes into making a decision on eco-toxicity. The set of parameters we propose
encapsulate many aspects of the evaluation but are by no means exhaustive. Similarly, we the set of
actions and associated rules could be expanded to fit more situations.
We recommend that Natura continue to seek new parameters and to question whether the
recommended set of actions is appropriate. Once the actions are determined and the set of parameters
is updated, our experience has been that it is surprisingly easy to describe in words what the rules
should be. However, one caveat is that we did not have to convince many stakeholders that our rules
were appropriate. We imagine that it could be challenging to calibrate the rules in a way that it pleases
people in finance, in operations, and in procurement all at the same time.
One source for new ideas is to conduct further research on tools of risk evaluation. At this time, it
appears that most corporations, not only in the cosmetic industry but in others as well, are trying to
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figure out the best tools and processes to manage eco-toxicity. One way for Natura to generate interest
and information sharing among industry players would be to share its approach with the public at large.
This could be the start of a discussion where Natura could be leader in shaping the industry wide
perspectives.
5.6.2 Test in practice
We have barely scratched the surface in terms of testing how well the decision framework would work
in practice. An essential next step would be to determine what Natura wants to achieve strategically
from the eco-toxicity management. If such a tool becomes part of the decision making process, then the
company would have to build organizational structure to lead and support Natura’s company-wide
initiative on eco-toxicity management. There needs to be a clear commitment to three main activities.
Natura should put in place the IT systems to support the data acquisition process for all
ingredients and their substitutes
Natura should assign a cross-functional team to come up with, and review periodically the set of
business rules that the company wants to apply to the data
The upper management of the company will need to drive the effort and incorporate the
decision framework into their agenda
Each of these activities is necessary for the decision framework to work in practice. Once these are in
place, then decision framework would probably need to be revised and adjusted in ways we cannot
predict.
5.6.3 Objectives and goals
As mentioned earlier, the decision framework is an analytical tool to support sound human judgment.
With or without the tool, Natura should continue to set specific objectives that will serve as the guiding
light the eco-toxicity initiatives. These objectives need to be measureable, specific, and aligned with
Natura’s corporate strategy.
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6 Conclusion
Through this project, we found the area of eco-toxicity management is still under development. We
could not find fully established risk assessment tools, let alone a management framework for decision-
making in a business setting; however, managing the environmental risk of ingredients and products is
becoming more and more important, given the high volume and growth of chemical industry, and
concerns for sustainability by various stakeholders including consumers, regulatory bodies, and
manufacturers.
In our attempt to make a supportive tool for Natura’s decision-making to deal with eco-toxic
ingredients, we incorporated not only scientific risk-related data of ingredients but also other factors
such as profitability of products, substitutability of alternative ingredients, policy level, and public
perception into our model. All of the information is necessary to evaluate and prioritize actions in a
resource-limited business setting.
Although our research is not exhaustive and our decision framework is not perfect, we, as a team,
learned that:
Making data hypothesis when missing data enables progress making on a model. We initially
thought we would not be able to finalize our model without the detailed set of data that fit
perfectly in pre-defined boxes.
Stepping back and considering eco-toxicity as a broad issue, not just specific to the cosmetics
industry, results in obtained more and higher quality information. There are good practices in
each industry that can be applied to cosmetics.
We hope that Natura will use the outputs of this project as a starting point of eco-toxicity management
and evolve the framework into a more sophisticated one. As mentioned in 5.6 Next Steps, this will
require company-wide, cross-functional efforts to collect necessary data and make comprehensive
decisions as a company. Tools and models are useful in supporting decision-making but they cannot
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replace human judgment.
From a broader perspective, we think Natura and the society could benefit if Natura could lead
initiatives in cosmetic industry in Latin America, beyond one company’s initiative. The model we
proposed in this paper will be available to other companies as well after removing proprietary data. It is
critical to address the eco-toxicity management issue as an industry in order to collectively prioritize
actions and mitigate risks from the aggregated release of chemicals from multiple companies. The
collective approach saves the cost through sharing necessary scientific data as well. One possible
approach would be for Natura to lead a launch of consortium or alliance for the cosmetics industry. By
strategically collaborating with other players in the chemicals and cosmetics field, we think Natura can
further contribute to the well being of people and planet.
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7 Appendix
7.1 Appendix 1 – Key Research References
Name Resource
Alternatives Assessment Framework
http://www.chemicalspolicy.org/alternativesassessment.lowellcenter.php
California Green Chemistry Initiative
http://www.dtsc.ca.gov/pollutionprevention/greenchemistryinitiative/index.cfm
Clean Production Action’s GreenScreen
http://www.cleanproduction.org/Greenscreen.php
Cosmetics Directive http://ec.europa.eu/consumers/sectors/cosmetics/documents/directive/
The European Chemical Industry Council
http://www.cefic.org/
EWG’s Skin Deep http://www.ewg.org/skindeep/
Exposure and Risk Screening Methods for Consumer Product Ingredients
http://www.aciscience.org/docs/Exposure_and_Risk_Screening_Methods.pdf
Goodguide http://www.goodguide.com/#
HERA http://www.heraproject.com/Initiative.cfm
International Council of Chemical Associations
http://www.icca-chem.org/
Japan Soap and Detergent Association
http://jsda.org/
MBDC’s Cradle to Cradle Design
http://www.mbdc.com/detail.aspx?linkid=1&sublink=6
The OECD Environmental Risk Assessment Toolkit
http://www.oecd.org/document/54/0,3746,en_2649_34379_44909430_1_1_1_1,00.html
PBT Profiler http://www.pbtprofiler.net/default.asp
Product Design and Development
Book authored by Karl T. Ulrich, Steven D. Eppinger
REACH http://ec.europa.eu/environment/chemicals/reach/reach_intro.htm
Scorecard http://scorecard.goodguide.com/
SC Johnson’s Green List Process
http://www.scjohnson.com/en/commitment/focus-on/greener-products/greenlist.aspx
US EPA’s Design for Environment
http://www.epa.gov/dfe/alternative_assessments.html
7.2 Appendix 2 – Contact information of people we connected with
Name Function Contact information Key Points of Discussion Dr. Edgar Blanco Research Director at Center for
Transportation and Logistics,
MIT
(617) 253-3630
Should Natura tackle the issue in a consortium?
TESCO funded an NGO to assess carbon footprint of its products after finding it too costly trying to do it internally for 7 years
Wal-Mart built a consortium with suppliers to reduce operating costs
Steven D. Eppinger Professor of Management
Science and Innovation at MIT
Sloan School of Management
(617) 253-0468
Introduction of H2NO jackets by Patagonia in addition to Teflon jackets
Herman Miller’s introduction of environmental friendly chairs replacing
PVC with polypropylene
Elsa Olivetti Research Scientist at Materials
Systems Laboratory, MIT
(617) 253-8468
Applications of Clean Production Action’s Green Screen tool
California’s Green Chemistry Initiative
Bill Pease Chief Scientist at GoodGuide [email protected] Eco-effects in cosmetics are not scrutinized because:
Cosmetics are not a large source for environmental releases
Few ingredients have significant effects with global reach
Mark Rossi Policy Director, Clean Production Action Chair at BizNGO
rg
Review of Assessment tools such as US EPA Integrated Risk Information
System (IRIS), Cosmetic Ingredient Review (CIR) and EU Risk Phrases
Naohiro Takahashi President, Sumitomo Chemical
America
n2takahashi@sumichem.
com
Overview of trends of the regulations and management of chemicals
How businesses should incorporate not only cost benefit analysis at a
company level but also its impact on society into the decision making
Martin H. Wolf Director, Product Sustainability
and Authenticity at Seventh
Generation, Inc.
mhw@seventhgeneration
.com
Emphasis on the use of only safe ingredients to make products
Companies responsibility extends to the use phase of cosmetics and
educating the customer is included in good practices
Romulo Zamberlan Portfolio Innovation Manager
at Natura romulozamberlan@natur
a.net Natura’s ongoing research on indigenous ingredients from the Amazon
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7.3 Appendix 3 – Comparative Analysis of Hazard, Exposure and Alternatives Assessment Tools
Tool Organization What it offers What it does not offer
Assessing Hazard
PBT Profiler Environment Science Center, US EPA
Estimates persistent, bio-accumulative and toxic profiles for organic chemicals
given their CAS Registry number
Does not assess exposure of chemicals Indicates hazard using color codes - green, orange and red, for e.g.
P B T – high hazard
P B T – low hazard
Skin Deep Environment Working Group, US
Contains safety assessment for 70,000 cosmetic products and ingredients
based on a Hazard Score Framework that comprises 17 hazard categories including ecotoxicology and persistence and bioaccumulation
Relative weight assigned to eco-toxicity
is only 3% of the hazard rating
Assigns numeric ratings between 0-10 to reflect low (0), medium or high (10)
concern, for e.g.
Does not assess exposure of products
or ingredients
DMDM Hydantoin rates 7-8 based on hazard and data availability
GoodGuide GoodGuide, US based For-Profit
Provides authoritative information about health, environmental and social
performance of products and companies
Environment summary score makes no
direct reference to eco-toxicity
Products ratings range from 0-10, with higher scores associated with better
products, for e.g. Product X may be assigned: Ratings do not measure exposure
Total Score – 6.8 ( Health – 8.0, Environment – 7.0, Society – 5.4) Natura's products are not assigned complete
scores because of partial data availability
Scorecard GoodGuide, US based For-Profit
Measures toxic chemical releases in air and water by about 20,000 industrial
facilities in the US
Does not allocate what part of the toxic
releases come from the cosmetics industry
Requires area zip code or name of company and provides information about
pollution and toxic chemicals based on Toxic Release Inventory (TRI) sources, for e.g. Company X, Total Environment Releases – 15.9 million pounds
Does not measure toxic releases from
consumer-use phase
Assessing Hazard and Exposure
Human and Environmental Risk Assessment (HERA)
European initiative between AISE, the makers of household cleaning products and CEFIC, the chemical industry
Provides a risk assessment framework for evaluating safety of high tonnage
chemicals in the household cleaning products industry
Focuses only on cleaning products and
chemicals
Unlike OECD’s High Production Volume (HPV) chemical assessment program
or US EPA’s HPV Challenge program that primarily focus on hazard assessment, HERA assesses both hazard and risk of chemicals
Is still work in progress
4
Tool Organization What it offers What it does not offer
Guidance for Ecological Risk Assessment
Green Chemistry Initiative (GCI) under California Department of Toxic Substances Control (DTSC)
Describes a phased method of conducting both hazard and exposure
assessment for chemicals at permitted facilities
Does not assess exposure of chemicals
during or post the consumer use phase Promotes design of chemical products and processes that reduce or eliminate
the use and generation of hazardous substances
Assessing Alternatives
Alternatives Assessment Criteria for Hazard Evaluation
Design for Environment (DfE), US EPA
Provides transparent tool to seek safer chemicals for health and environment
Very few chemicals identified for risk
assessment are relevant for the cosmetics industry
Uses US EPA’s Chemical Action Plans for identifying chemical candidates for
risk management
Action Plans summarize available hazard, exposure, and use information for
chemicals and outline their risks
Green Screen for Safer Chemicals
Clean Production Action, US
Complements the DfE Alternatives Assessment methodology to aid in the
selection of safer alternative chemicals
Proposes greener chemicals based on
hazard assessment, not on exposure Defines benchmarks for use of safer chemicals, such as:
o Avoid chemicals of high concern
o Use but search for safer substitutes
Alternatives Assessment Framework
Lowell Center for Sustainable Production, US
Provides Guiding Principles for prevention, precaution or substitution of
chemicals
Serves as a generic tool for
alternatives assessment
Contains Comparative Assessment of existing chemicals and Design
Assessment of new chemicals
No direct examples in the cosmetics
industry
Evaluates alternatives based on health, environment, social justice, economic
feasibility and technical performance
CleanGredients GreenBlue, US based non-profit and US EPA
Identifies cleaning product ingredients that are safer for human health and
environment Does not assess exposure of chemical
ingredients Ingredient modules include solvents and fragrances that can be used in the
cosmetics industry
5
7.4 End Note
1 International Council of Chemical Associations (ICCA), http://www.icca-chem.org/
2 The European Chemical Industry Council, http://www.cefic.org/
3 Natura Report 2010
4 Concept of Risk vs. Hazard (HERA) - http://www.heraproject.com/Risk.cfm
5 UNEP/IPCS Training Module No.3, Environmental Risk Assessment, http://www.chem.unep.ch/irptc/publications/riskasse/b2text.pdf
6 Environmental Risk Assessment, P&G, http://www.scienceinthebox.com/en_UK/safety/riskassenv_en.html
7 United Nations, Agenda 21, 2002, http://www.un.org/esa/dsd/agenda21/res_agenda21_19.shtml
8 SAICM, http://www.saicm.org/
9 ICCA, http://www.icca-chem.org/Home/ICCA-initiatives/Global-product-strategy/
10 ABIQUIM, http://www.abiquim.org.br/english/content.asp?princ=rec&pag=pre
11 EFfCI opinion on the Animal testing and Marketing Bans of the 7
th Amendment of the EU Cosmetics Directive, 2009,
http://www.effci.org/assets/files/EFFCI_PS/Amendment.pdf
12 Nature, 2009, The lowdown on animal testing for cosmetics, http://www.nature.com/news/2009/090311/full/news.2009.147.html
13 bibra technology advice & consulting, http://www.bibra-information.co.uk/
14 EU Cosmetics Directive, http://ec.europa.eu/consumers/sectors/cosmetics/documents/directive/#h2-summary-of-the-cosmetics-directive-76/768
15 Personal interview
16 The OECD Environmental Risk Assessment Toolkit: Steps in Environmental Risk Management
http://www.oecd.org/document/20/0,3746,en_2649_37465_44915476_1_1_1_37465,00.html
17 LION Corporation, http://www.lion.co.jp/en/
18 LION, CSR Report 2011, http://www.lion.co.jp/en/csr/pdf/csr_2011_15.pdf
19 LION, http://www.lion.co.jp/ja/company/rd/shien03.htm
20 LION, http://www.lion.co.jp/ja/csr/env/chemicals/
21 MBDC - http://www.mbdc.com/default.aspx